Tax Assessment Reopening: Reasons Must Be Based on Initial Material Facts, Not Enhanced by Later Affidavits or Arguments.

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....Reopening of assessment - Reasons to believe - The reasons itself indicates that the material fact was picked up from the Profit & Loss Account Notes 26 and the statement of computation of income while arriving at the income as per normal provisions. - It is settled law that what is not there in the reasons cannot be improved upon in the affidavit or during the course of argument. - HC....