Assessment cannot be reopened u/s 147 Based on Material Assessed by AO in Original Assessment

Shri Dinesh Kumar Gupta Vs ITO (ITAT Agra) The issue under consideration is whether reopen assessment u/s 147 based on the same material which is examined by AO in original assessment is justified in law? ITAT states that, the reasoning for reopening as mentioned in the assessment order clearly shows that the same material which was considered by the Assessing Officer in the original assessment order was again considered by the Assessing Officer in the re-assessment order and based on that, the reassessment proceedings were finalized and income of the assessee was computed. In our considered o...