#Section 147
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Prima Facie some material is required not sufficiency or correctness for valid reopening u/s 147
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Section 147: Assessee cannot be put to mercies of careless, casual, arbitrary or whimsical exercise of power
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Section 147 assessment based on specific, relevant & reliable information is valid: SC
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Non Disposal of Objections Before Concluding of Assessment With Separate Speaking Order Makes Assessment Nullity
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Section 147 or 153C Assessment – Search from 3rd party premises – Unexplained Money addition under Section 69A
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Reopening based on mere Shah Commission Report not Valid if no Application of Mind by AO
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‘Reasons to Believe’ is Different from ‘Reasons to Suspect’: SC
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Analysis of sections 147, 148, 148A, 149 and 151 of Income Tax
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No reassessment merely for Loan Advancement or Non filing of ITR
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Section 147 proceedings not identical to section 143(2) proceedings
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Section 147 Reopening invalid if made without following mandate of Section 147,148 & 151
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No reassessment if AO fails to bring new material on record
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Reassessment based on Incorrect/Non-Existing reasons is Illegal & Bad in Law
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