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Reopening of assessment was upheld where the assessing officer formed a prima facie belief of income escapement after examining return and investigation material; sufficiency of reasons requires relevant material and a rational connection and need not be a prior detailed inquiry. Payments made to an accommodation/entry provider were treated as unexplained expenditure taxable in the year of payment under the unexplained money regime rather than purchases of earlier years. The omission to cite the specific statutory provision in the assessment order was held immaterial where the assessee was repeatedly informed of the nature and tax consequences of the payment.
Reopening of assessment was upheld where the assessing officer formed a prima facie belief of income escapement after examining return and investigation material; sufficiency of reasons requires relevant material and a rational connection and need not be a prior detailed inquiry. Payments made to an accommodation/entry provider were treated as unexplained expenditure taxable in the year of payment under the unexplained money regime rather than purchases of earlier years. The omission to cite the specific statutory provision in the assessment order was held immaterial where the assessee was repeatedly informed of the nature and tax consequences of the payment.
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