Assessment Reopening Invalid: Audit Report Alone Can't Justify u/s 148; Full Disclosure Made by Assessee.

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....Validity of Reopening of assessment u/s 147 - Reopening on the basis of the report of the Centralized Audit Unit, CAG - Different Apex Court pointed out that the audit report cannot be the basis for re-opening u/s. 148 of the Act. Further, there is no failure on the part of the assessee to disclose fully and truly all material facts necessary for this assessment. There is no reason to believe that the income has escaped assessment during the year. - AT....