Re-Opening of Assessment u/s 147 Merely Relying upon Investigation Report Not Justified in Law

Eminent Computers Pvt. Ltd. Vs ITO (ITAT Delhi) The issue under consideration is whether the re-opening of assessment u/s 147 merely relying upon investigation report is justified in law? ITAT states that the return of income filed by the assessee has also been analyzed with reference to the information received from the Investigation Wing and keeping in view the factual position found by the Investigation Wing on the basis of documents seized in the search operation and post search inquiries, as discussed above. Considering all these material in totality there is enough material on record to ...