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HC allowed the petition and set aside the impugned order and notice u/s 148A(b). AO failed to establish that petitioner had received any amount exceeding Rs. 50,00,000/- which escaped assessment. AO is required to form an opinion based on credible information contradicting petitioner's assertion that aggregate transaction value was less than Rs. 50,00,000/-. Merely stating transactions existed without substantiating higher value is insufficient for reopening assessment u/s 147.
HC allowed the petition and set aside the impugned order and notice u/s 148A(b). AO failed to establish that petitioner had received any amount exceeding Rs. 50,00,000/- which escaped assessment. AO is required to form an opinion based on credible information contradicting petitioner's assertion that aggregate transaction value was less than Rs. 50,00,000/-. Merely stating transactions existed without substantiating higher value is insufficient for reopening assessment u/s 147.
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