Reassessment Initiated u/s 147 Due to New Material; Notice Issued u/s 148 for Unconsidered Payments.

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....Reopening of assessment u/s 147 - AO has reasons to believe that such payments which were not considered during the original assessment escaped assessment and therefore, notice u/s 148 was issued. Once a tangible new material is identified and such materials were not considered by the assessment officer while at the time of passing original assessment order, it is sufficient to reopen the assessment and it is for the petitioner to defend his case by availing the opportunities to be provided during the course of the reopening proceedings. - HC....