Reopening under s.147 invalid where AO delayed four years; disclosure under s.139(1) negated need for third-party confirmations

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....ITAT held that the reopening of assessment under s.147 was invalid where the AO sat on information from the Investigation Wing for over four years and did not satisfy conditions of the first proviso to s.147 before issuing notice; the assessee had fully disclosed purchases in the return filed u/s 139(1) and produced delivery challans, receipts and particulars of subsequent sales, and there was no legal obligation to furnish third-party confirmations at that stage. The reassessment framed u/s 143(3)/147 and the ad hoc profit enhancement were quashed as bad in law, and the assessee's appeal was allowed.....