Sec. 147 Income-tax Act, 1961— Reassessment — Identifying and recording of "reasons to believe" is a pre-requisite for the AO to assume jurisdiction under s. 147 of the Act, as per the scheme . New facts, material or information have come to the knowledge of the AO by way of the report of Director of IT with regards to the doubtful source of the investments made into the petitioner companies and at the time of original assessment, the AO was not aware of or in possession of information which could have indicated that the introduction of share capital from outside India has been routed through a doubtful entity, therefore, even if scrutiny assessment has been undertaken in the first place, if significant new material is found in the form of information, the AO can form a belief that the income of the assessee has escaped assessment, and reopen assessment, thus, the recorded reasons are not mere change of opinion — EXPERION HOSPITALITY (P.) LTD. Vs. ASSTT. CIT [2020] 313 CTR 384 (DEL)