Reassessment u/s 147 Quashed Due to Invalid "Reasons to Believe"; Appellate Orders Also Invalidated.

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....Validity of Reopening of assessment u/s 147 - eligibility of reasons to believe - initiation of reassessment proceedings u/s.147 of the Act, issuance of notice u/s.147 of the Act, impugned reassessment order as well as first appellate order are hit by second limb of first proviso to section 147 of the Act, therefore, on this count entire action of the AO including impugned reassessment order and first appellate order deserves to be quashed. - AT....