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of Reopening of assessment u/s 147 - upon purchase of the flat, the purchaser certainly acquires a right or interest in the proportionate share of the land but its realisation is deferred till formation of the co-operative society by the flat owners and transfer of the entire property to the co-operative society - There was no basis or justification to form a belief that any income of the assesee chargeable to tax for the assessment years under consideration had escaped assessment
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