Reopening Tax Assessments Needs Solid Justification; Mere Claims of Non-Disclosure Insufficient u/s 147 Proviso.

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....Reopening of assessment u/s 147 - proper reasoning - Merely by adding a line in the reasons recorded by the Assessing Officer that the assessee had failed to disclose fully and truly all material facts, requirement of proviso to section 147 of the Act would not be satisfied for the purpose of reopening of the assessment u/s 147 - AT....