Entire law on whether reopening of assessment in the absence of "fresh tangible material" is permissible reviewed

CA Suraj R. Agrawal Facts of the case: a. Assessee had filed return of income on 27-10-2006 u/s 139(1) and original assessment was done by AO u/s 143(3) vide order dated 15.12.2008. b. Subsequently, this case was reopened u/s 147 and AO framed re-assessment order dated 31.12.2012 u/s 143 read with 147 of the Income Tax Act 1961. c. Against this, the Assessee filed an appeal before Ld. CIT (A), wherein he challenged the action of the AO of re-opening of assessment u/s 147 and also challenged additions made by the AO on merits. d. Ld. CIT (A) did not accept the submissions of t...