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      Reopening of assessment u/s 147 - reason to believe - the...

      Reassessment Void: AO Failed to Independently Justify Belief of Escaped Income, Confusing Suspicion with Belief.

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      Income TaxJanuary 6, 2024Case LawsHC
      Reopening of assessment u/s 147 - reason to believe - the reassessment proceedings were triggered without the AO applying his own mind and articulating his reasons as to why he believed that the material available with him was indicative of the fact that the income which was otherwise chargeable to tax had escaped assessment. As correctly submitted, in law reasons to suspect are markedly different in quality and texture from reasons to believe. - HC

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      ActsIncome Tax