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Reopening of assessment u/s 147 - addition as concealed income u/s. 69 - The fact that the assessee has consistently alleged connivance of the bank authorities coupled with the fact that the currency details and lack of PAN details of the depositor evident on record remain unrebutted on record by the tax authorities cannot be allowed to remain ignored. In the facts as they stand unless these assertions are rebutted by cogent evidence, the assessee appears to have a claim which cannot be easily discarded - Matter remitted back for fresh adjudication - AT
Reopening of assessment u/s 147 - addition as concealed income u/s. 69 - The fact that the assessee has consistently alleged connivance of the bank authorities coupled with the fact that the currency details and lack of PAN details of the depositor evident on record remain unrebutted on record by the tax authorities cannot be allowed to remain ignored. In the facts as they stand unless these assertions are rebutted by cogent evidence, the assessee appears to have a claim which cannot be easily discarded - Matter remitted back for fresh adjudication - AT
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