Reassessment u/s 147 not permitted for failure of AO to draw correct inference from details disclosed by assesse

Brief of the case: Punjab & Haryana High Court held in CIT(A) Vs M/s ITW India Limited that mere change in opinion of the AO could not amount to issue of notice for re-assessment u/s 147. AO should had reasonable tangible facts in hand before issuing notice u/s 147. Moreover notice u/s 147 could not be issued beyond four years from the relevant assessment years. Further it was the duty of the AO to analyse into the facts/ documents presented before AO during scrutiny proceedings, later on it could not be said by the AO that assesse had not disclosed the facts fully which would build reaso...