No section 147 notice based on material already presented during section 143(3) assessment

Advertisement Audhut Timblo Vs ACIT (Bombay High Court- Goa Bench) The issue under consideration is whether A.O. is correct in issuing Notice under section 147 for re-opening of assessment irrespective of the fact that the material on which he relied is already present in front of him at the time of assessment u/s 143(3)? In the present case there was full disclosure and in fact, the amount had even become the subject matter of the assessment both under Section 158BC and Section 143(3) of the I.T. Act, there could have been no reason to believe that the income chargeable to tax had indeed e...