Court Challenges Assessment Reopening: AO Lacked Clear "Reason to Believe" u/s 147, Failed to Apply Mind Adequately.

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....Reopening of assessment u/s 147 - reason to believe - the Ld. AO has absolutely changed his view which was formed initially and which was formed while concluding the assessment. Therefore, the statutory provisions per ‘reasons’ and contents in ‘assessment order’ are distinct which shows that the reasons were not on account of application of mind on the part of AO. Thus it is a clear case of lack of basic ingredient of section 147 i.e. “reason to believe”, as AO himself was not able to decide about the legal provisions which are being attracted in the given case. - AT....