Court Invalidates Assessment Reopening u/s 147 Due to Lack of Disclosure of "Reasons to Believe" Material.

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....Reopening of assessment u/s 147 - We are of the opinion that shorn of all other technical aspects which may have been raised before us, the very fact that the material referred to in the “reasons to believe” was not supplied to the petitioner, the entire proceedings for the reopening of the assessment and leading to the consequential assessment stand vitiated in law. - HC....