Assessee runs race club and claimed losses that was partly allowed by CIT(A). On reopening u/s 147, the same issue was considered by CIT(A) again and this time he confirmed the addition. On appeal, the Tribunal held that the AO had no fresh tangible material but based the reopening on the material available in the assessment records which was also taken up to the CIT(A). Reassessment is not valid. (AY 2007-08)