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The Income Tax Appellate Tribunal held that the Assessing Officer had rightly formed a 'reason to believe' and not merely a 'reason to suspect' regarding escapement of income based on the assessee's investment in property being disproportionate to their disclosed income. The approval u/s 151(2) for reopening assessment was properly granted after due application of mind by the Principal Commissioner. However, the Tribunal directed deletion of the addition made u/s 69 regarding unexplained investment, as the assessee had duly explained their share of the investment, while leaving the issue of unsecured loan and jewellery amount received by the assessee's wife to be examined separately.
The Income Tax Appellate Tribunal held that the Assessing Officer had rightly formed a 'reason to believe' and not merely a 'reason to suspect' regarding escapement of income based on the assessee's investment in property being disproportionate to their disclosed income. The approval u/s 151(2) for reopening assessment was properly granted after due application of mind by the Principal Commissioner. However, the Tribunal directed deletion of the addition made u/s 69 regarding unexplained investment, as the assessee had duly explained their share of the investment, while leaving the issue of unsecured loan and jewellery amount received by the assessee's wife to be examined separately.
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