Reopening Assessment u/s 147 Invalid Without New Evidence or Assessee's Failure to Disclose Material Facts.

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....Reopening of assessment u/s 147 - necessary conditions for initiating and completion - the reopening of the assessment made by the learned assessing officer is not on account of the failure on part of the assessee to disclose fully and truly material facts for assessment of income as well as there is no tangible material available with the assessing officer to reopen the assessment. All the catena of judicial precedents cited before us also laid down the same principles - AT....