Availability of tangible material is pre-conditional for reopening of assessment

Valco Industries Ltd Vs ACIT (ITAT Chandigarh) Facts- The assessee originally filed return declaring total income of Rs.4,83,83,620/- on 28.09.2012 after claiming deduction of Rs.5,75,64,789/- u/s 80IC of the Act. The assessment was completed u/s 143(3) of the Act on 27.03.2015 at an income of Rs.8,07,03,620/- after making an addition of Rs.3,23,20,000/- on account of share of assessee company in industrial property by making the calculation of the share of the assessee company at 20%. Subsequently, notice u/s 148 of the Act dated 10.03.2017 was issued. In response to the notice issued u/s 148...