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ITAT upheld the validity of reassessment initiated under section 147, holding that subsequent CBDT Notification No. 3/2019 withdrawing approval of the donee institution, Bioved Research Society, with retrospective effect constituted fresh, tangible material indicating misuse of section 35(1)(ii) through accommodation entries. The AO's formation of belief that income had escaped assessment was found to be neither imaginary nor based on change of opinion. Consequently, the Tribunal sustained the disallowance of the assessee's Rs. 30 lakh donation and denial of deduction under section 35(1)(ii), deciding the appeal against the assessee.
ITAT upheld the validity of reassessment initiated under section 147, holding that subsequent CBDT Notification No. 3/2019 withdrawing approval of the donee institution, Bioved Research Society, with retrospective effect constituted fresh, tangible material indicating misuse of section 35(1)(ii) through accommodation entries. The AO's formation of belief that income had escaped assessment was found to be neither imaginary nor based on change of opinion. Consequently, the Tribunal sustained the disallowance of the assessee's Rs. 30 lakh donation and denial of deduction under section 35(1)(ii), deciding the appeal against the assessee.
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