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    <title>2017 (12) TMI 1908 - ITAT AHMEDABAD</title>
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    <description>Reopening of assessment under section 147 requires relevant material giving rise to a bona fide, prima facie belief that income has escaped assessment; a mere desire for detailed verification of third-party information is insufficient. On the recorded reasons, the Assessing Officer only referred to information from a third-party search and a need to investigate transactions, which did not satisfy the jurisdictional precondition for reopening. The notice was therefore without authority of law, the reassessment was quashed, and the merits of the additions were not examined; the time-limit objection was not separately decided once invalidity of the reopening was found.</description>
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      <link>https://www.taxtmi.com/caselaws?id=468307</link>
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