Court Rejects Tax Reassessment Based on Old Material; New Info Required u/s 147 of Income Tax Act.

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....Reopening of assessment u/s 147 - Eligibility of reasons to believe - there is nothing new and it is, in fact, the very note filed by the assessee as well as material that was available on record that has been invoked by the Assessing Officer to reopen the assessment. The counter filed by the Department makes a lukewarm attempt to defend the impugned proceedings by stating that only a 'half page note' had been filed by the assessee which would not suffice. - This defence is only stated to be rejected. - HC....