1, Bhubaneswar dated 27.6.2017 for the assessment year 2009- 2010. 2. Ground No.1 of appeal reads as under” “ For that the impugned order of assessment passed by the Ld. A.O u/s.147 of the Act, to reopen the assessment, is legally impermissible particularly there were no tangible materials available on record in order to reopen the assessment, as such the appellant