Court Rules AO's Reopening of Assessment Invalid: No Failure to Disclose, No Existing Agreement u/s 147.

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....Reopening of assessment u/s 147 - Non production of agreement before the AO - It is nobody’s case that there existed any such agreement, which ought to have been produced but was not produced. Rather AO intends to imply that in the absence of any such agreement, the benefit ought not to have been granted to the Petitioner in the scrutiny assessment. There cannot be any failure to disclose fully and truly, if there was no such document as such. This, in our opinion, is nothing but a change of opinion - HC....