S.147 [HC Guj] [In favour of Revenue] Re-opening , No return of income filed. Material available (from I&CI, Inv. Etc.) is tangible(vaild)

Section 147   
Court :  Gujarat High Court
[In favor of Revenue : ]
Citation :   2017-TIOL-1423-HC-AHM-IT  SPECIAL CIVIL APPLICATION NO. 12152 of 2017
Case Name : Mona Mahesh Bhojani Vs ITO 

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Reopening initiated in case of an assessee who had not filed his return, cannot be claimed by the assessee to be based on 'change of opinion'. when the AO has tangible material at his command to form a bonafide belief that income chargeable to tax has escaped assessment, the writ court would not interfere with the formation of such belief unless it is shown to be wholly perverse

S.147 ,in favour of Revenue, HC Guj: Re-opening , No return of income filed. Material available (from I&CI, Inv. Etc.) is tengible.