Section 147 & 148 of Income Tax Act, 1961 — Reassessment — Reasons must be based on new and tangible material and notice based on documents already on record not valid. It is well settled Law that validity of re-assessment proceedings is to be determined with reference to the reasons recorded for reopening of the assessment. The notice under section 148 have been issued after 04 years and no new and tangible material has been brought on record at the time of reopening of the assessment and the A.O. wanted to correct the error in the original assessment order passed by the A.O. while initiating the re-assessment proceedings, thus, reopening of the assessment is not valid in the facts and circumstances of the case — Alcatel Lucent India Ltd. vs. Asstt. CIT [2020] 77 ITR [Trib] 694 (DEL)