Reopening for not considering a SC Judgment in original assessment not valid

Brief of the Case Delhi High Court held In the case of Coperion Ideal Pvt. Ltd. vs. CIT that threshold requirement of re-opening of assessment that the AO should, on the basis of some tangible material, conclude that there was escapement of income on account of the Assessee failing to disclose material particulars, is not fulfilled in the present case. Consequently, the reopening of the assessment was not justified. The mere fact that there was a judgment of the Supreme Court of 1997 which was not noticed by the AO when he framed the original assessment cannot per se constitute the only materi...