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of The HC held that reopening the assessment under Section 147 against the joint owner wife was unsustainable, as there was no reason to believe that her income had escaped assessment for AY 2021-22. The wife did not contribute financially to the property purchase, which was fully funded by her husband, supported by bank statements. The Section 148 notice issued to her was invalid since the AO's belief of escapement was unfounded. The Court relied on precedent where a similar reassessment against a non-earning spouse was quashed due to lack of evidence linking the property purchase to her income. Consequently, the wife's appeal was allowed, setting aside the reopening notice and assessment proceedings against her.
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