Reopening assessment invalid-AO didn't record non-disclosure; 2nd reopening on share premium-based on impermissible change of opinion.

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....Reopening of assessment u/s 147 was invalid as Assessing Officer (AO) failed to record that assessee did not disclose fully and truly all material facts necessary for assessment. For second round of reassessment on share premium received, reopening was based on change of opinion, which is impermissible. Investigation wing's report alone is insufficient as survey statements lack evidentiary value. Failure to disclose survey details in first reopening does not constitute failure u/s 147. Decided in assessee's favor.....