Reopening Tax Assessment u/s 147 Not Justified by AO's View of Insufficient Evidence from Assessee.

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....Reopening of assessment u/s 147 - merely because the AO finds the proof submitted by the assessee at the time of assessment proceedings to be not sufficient for the purpose of admitting the claim - it cannot be said that there was any failure on the part of the assessee so as to invoke the provisions of section 147 - HC....