Court Upholds Reassessment u/s 147; Establishing Donor Identity and Payment Method Insufficient for Gift Genuineness.

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....Validity of reopening u/s.147 - addition u/s.69A on account of gifts - reasons recorded were sufficient to clothe the Assessing Officer to acquire the jurisdiction, to reopen the assessment - in the case of the gift mere identity and payment through account payee cheque does not establishes the genuineness of the gift - AT....