High Court: No Reopening u/s 147 Without New Evidence; Section 144C Failure Insufficient for Sections 147/148 Actions.

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....Reopening of assessment u/s 147 - material which was examined and qua which opinion was rendered by the AO while passing the draft assessment orders - The failure to arrive at a logical conclusion in a Section 144C proceeding cannot become the ruse for initiating the proceedings under Section 147/148 of the Act in the absence of new material emerging before the AO which gives the AO reason to believe that assessee's income chargeable to tax had escaped assessment - HC....