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of Reopening of assessment u/s 147 - Unexplained cash credit - penny stock purchases - AO was aware of the fact that the script of Shreenath was allegedly a penny stock company as it is clear from the annual information report given by the Assessing Officer himself to petitioner alongwith the first notice. Therefore, there is no question of any further information on the same issue being treated as information so as to justify the reopening of the assessment.The expression 'reason to believe' in Section 147 of the Act has been held to mean a cause or justification. - HC
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