Assessment was   reopened  on  the  ground that a search conducted at DSC Group of Companies revealed bogus purchases made by assessee through unexplained sources.  The Assessing Officer made the addition which was confirmed by the CIT(A). On appeal the Tribunal  held that  the reasons recorded by Assessing Officer did not make specific allegations of failure to disclose all material facts, which was a prerequisite for reopening under section 147 and mere search action alone could not justify reopening of assessment. As the jurisdictional ingredients for reopening assessment provided in first proviso to section 147 were absent, both in form and substance and therefore, proceedings were bad in law. On appeal High Court affirmed the order of the Tribunal. (AY. 2006-07)