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Challenge to Reopening Assessment: Lack of Rationale by AO on Unpaid Loan Liability u/s 147 Questioned.

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Full Text of the Document

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....Reopening of assessment u/s 147 - unpaid loan liability - AO has not shown any rational for involving Section 56 to the transaction of loan. The reasons are completely and wholly silent as to how the provisions of Section 56 are attracted in respect of outstanding liability of loan. Moreover, the reasons also do not spell out as to how there has been escapement of income by the assessee.....