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Reopening of assessment u/s 147 was done solely for the purpose of verification of the source of purchase of property, which is not a valid reason as per settled judicial precedents. The Bombay High Court in Nivi Trading Ltd. v. Union of India has categorically held that reassessment u/s 147 cannot be done solely for verification purposes. Since reopening was done only for verification of source of investment in property, as evident from the reasons recorded by the Assessing Officer, relying on the judicial propositions that reopening cannot be done for verification, the reopening of assessment is held invalid and unjustified, and consequently, the assessment order does not survive. The appeal is allowed on this ground.
Reopening of assessment u/s 147 was done solely for the purpose of verification of the source of purchase of property, which is not a valid reason as per settled judicial precedents. The Bombay High Court in Nivi Trading Ltd. v. Union of India has categorically held that reassessment u/s 147 cannot be done solely for verification purposes. Since reopening was done only for verification of source of investment in property, as evident from the reasons recorded by the Assessing Officer, relying on the judicial propositions that reopening cannot be done for verification, the reopening of assessment is held invalid and unjustified, and consequently, the assessment order does not survive. The appeal is allowed on this ground.
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