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Non-confirmation of FEMA seizure prevents adjudicators from overriding pending appellate findings on recorded reasons and suspected foreign asset hold...
Validity of reopening of assessment u/s 147 - Reason to believe - The Appellate Tribunal observed that the reassessment proceedings were initiated solely based on the information available in Form 26AS, without any fresh material or tangible evidence. The Tribunal agreed with the CIT(A)'s conclusion that the AO did not have sufficient grounds to form a belief that income had escaped assessment. Therefore, the Tribunal dismissed the revenue's contention and upheld the CIT(A)'s decision to quash the reassessment proceedings.
Validity of reopening of assessment u/s 147 - Reason to believe - The Appellate Tribunal observed that the reassessment proceedings were initiated solely based on the information available in Form 26AS, without any fresh material or tangible evidence. The Tribunal agreed with the CIT(A)'s conclusion that the AO did not have sufficient grounds to form a belief that income had escaped assessment. Therefore, the Tribunal dismissed the revenue's contention and upheld the CIT(A)'s decision to quash the reassessment proceedings.
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