Reopening of assessment u/s 147 without tangible material is unsustainable in law

Shujaat Ali Khan Vs ITO (ITAT Jaipur) Facts- Case of the assessee was reopened u/s 147 and notice u/s 148 was issued. The assessment U/s 143(3) r.w.s 147 was completed after making addition of Rs. 7,71,826/- being alleged undisclosed short-term capital gain on alleged sale of immovable property after invoking Section 50C of the Act. Assessee submitted that the reasons were recorded by the AO on the basis of CIB information and on the basis of said information and non-filing of return, it was concluded that the income has escaped the assessment. After recording the reasons, a notice u/s 133(6) ...