Section 147: Reopening Assessments Needs Tangible Link Between Material and Belief of Escaped Income, Not Just Investigation Info.

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....Reopening of assessment u/s 147 - Reasons to believe - When the AO has not created any link between tangible material and the formation of reason to believe that income had escaped assessment, then, the information received from Investigation Wing cannot be said to be tangible material per se without further inquiry being undertaken by the AO. - AT....