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Assessment Reopening u/s 147 Unjustified: Mere Offer Not Proof of Salary Income Without Definitive Evidence.
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....Reopening of assessment u/s 147 - Merely, offer made by the assessee in our considered view, ought not to have been taken as a conclusive evidence of earning salary income by the assessee. Therefore, in the absence of any conclusive evidence that the assessee infact had earned salary from M/s. Oldy Goldy Computers, the Assessing Officer was not justified in taking the addition and making the addition on account of earning of salary income - AT....