S. 147 : Reassessment-After the expiry of four years-Sale of shares-Tax Residency Certificate under laws of Mauritius-Capital gains-Nothing in form of information or material had been put on record-Reassessment notice is quashed and set aside-Matter was to be remanded back to AO to confront assessee with relevant material-DTAA-India-Mauritius. [S. 148, Art. 13, Art. 226]