Assessment Reopening u/s 147 Invalid Due to A.O's Mechanical Reliance on Incomplete Information from Directorate of Income-tax.

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....Reopening of assessment u/s 147 - we are of a strong conviction that as the A.O had failed to independently apply his mind to the ‘material’ available on his record and mechanically acting on the information supplied by the Directorate of Income-tax (Inv.) had on the basis of incomplete and incorrect facts reopened the case of the assessee u/s 147 of the Act. - AT....