Reopening Assessment u/s 147 Justified Due to New Tangible Evidence of Undisclosed Income, Allowing New Opinion Formation.

Reopening of assessment u/s 147 - there is prima facie tangible material to form an opinion that the income has escaped assessment and the assessee failed to disclose truly and fully all primary facts at the time of the previous assessment, as a result, the assessing officer could not draw proper legal inferences with regard to the alleged transaction. Therefore, as at the relevant time, there was no formation of opinion with regard to the alleged transaction, the assessing officer is not prohibited to form an opinion on the basis of the tangible material that came in his hands by way of information. - HC .....

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