Reopening Tax Assessment u/s 147 Requires New Material; No Fresh Evidence Means No Reopening Allowed.

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....Reopening of assessment u/s 147 - Reopning after 4 years - As per the mandate of law, even where a concluded assessment is sought to be reopened by the A.O within a period of 4 years from the end of the relevant assessment year, it is a must that the A.O has fresh material or information with him, that had led to the formation of belief on his part that the income of the assessee chargeable to tax has escaped assessment. - AT....