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AO solely relied on unspecified information categorized as 'high risk transactions' of unsecured loans without giving specific details of lenders, amounting to bald allegations. No definitive link or adverse document was present at the time of forming belief. Mere identification of transactions as 'high risk' cannot provide cause for reopening assessment. The reasons recorded give an impression of 'reason to suspect' rather than 'reason to believe' escapement of income as required u/s 147. The purported 'belief' is premised on vague grounds, failing the test of 'reason to believe'. ITAT allowed assessee's appeal.
AO solely relied on unspecified information categorized as 'high risk transactions' of unsecured loans without giving specific details of lenders, amounting to bald allegations. No definitive link or adverse document was present at the time of forming belief. Mere identification of transactions as 'high risk' cannot provide cause for reopening assessment. The reasons recorded give an impression of 'reason to suspect' rather than 'reason to believe' escapement of income as required u/s 147. The purported 'belief' is premised on vague grounds, failing the test of 'reason to believe'. ITAT allowed assessee's appeal.
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