Assessment Reopening Needs Assessing Officer's Belief of Escaped Income u/s 147 of Income Tax Act.

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....Reopening of assessment u/s 147 - The requirement of section 147 of the Act is the Assessing Officer has reason to believe that income chargeable to tax has escaped assessment. Assessing Officer’s reason to believe is sine-qua-non for reopening assessment. It is not the reason to believe of PCIT or any other authority which matters when it comes to the provisions of section 147 of the Act. - AT....