Reasons to reopen assessment must be tangible & should not merely be based on Investigation wing’s report

Brief about the case The assessee is a private Ltd. Company and it filed its return of income on 23.8.2004 declaring income of Rs. 11,000/-. The return of Income was processed u/s 143(1). Later notice u/s 148 of the Act dated 31.3.2011 was issued to the assessee. The assessee filed a reply dated 11.4.2001, wherein it has stated that, the return of income filed u/s 139 of the Act on 23.8.2004, be treated as a return filed in response to notice u/s 148 of the Act. The assessment was completed on 15.12.2011 u/s 147 r.w.section 143(3) determining total income of Rs.2,14,38,400/-. Aggrieved the ass...