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of ITAT upheld reopening under s.147 regarding inadequate consideration for immovable property purchase. Original assessment under s.143(1) had not examined the land purchase deed, constituting valid grounds for reassessment. On merits, addition under s.56(2)(vii)(b) was sustained as assessee failed to provide evidence of sale deed cancellation. Though assessee claimed cancellation was in process and produced co-purchaser's confirmation of non-payment, absence of seller's confirmation and non-refund of stamp duty indicated continuing validity of agreement. No change of opinion by AO was found. ITAT dismissed assessee's appeal, confirming additions made by AO and upheld by CIT(A).
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