Reopening of Tax Assessment u/s 147 Deemed Incorrect Due to Misconceived Basis, Jurisdiction Invalidated.

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....Reopening of assessment u/s 147 - 'reason to believe' - the assessee had not claimed any part of its income as exempt under Sec. 11(1)(a) of the Act - as the “reasons to believe” forming the very basis for taking recourse to proceedings u/s.147 of the Act in the case of the assessee are absolutely misconceived and incorrect, therefore, the very assumption of jurisdiction on the part of the A.O cannot be sustained and is liable to be struck down. - AT....