Court Rules Tangible Material Not Required to Reopen Assessment Under Income Tax Act Sections 147/148, Even Without Prior Assessment.

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....Reopening of assessment u/s 147 r.w.s. 148 - We reject the argument of AR that even in the case where there is no assessment made by the AO or the return is processed merely u/s 143 (1) of the income tax act, there is a requirement of having any tangible material with the assessing officer to reopen the case of the assessee. We hold that in such cases, there is no requirement of tangible material for reopening of assessment. - AT....