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    <description>Reopening was sustained where the assessing officer relied on external investigative material and verifiable indicia-non commensurate bank transactions, failed compliance with summons, adverse AIR data and field enquiries-to form a prima facie belief of escaped income, establishing a rational nexus to reassess. Payments to a suspected paper/entry provider were treated as unexplained expenditure taxable in the year of payment because no delivery or corroboration was produced; the assessment proceedings addressed the nature and tax consequences of those payments. Failure to cite the specific charging provision in the order did not vitiate the addition where the taxability was communicated and litigated during assessment.</description>
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