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Reassessment u/s 147 challenged due to lack of evidence; reopening based on assumptions, not facts.

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....Reopening of assessment u/s 147 - assessee had shown fixed assets but he had not offered any income from the said property - The reasons recorded by the Assessing Officer do not disclose that the assessee has used any of his assets for any business or rental purposes. The formation of belief by the AO in this case regarding the escapement of income of the assessee view is based on just assumptions and presumptions and there was no reliable material available with the AO to form the belief that the income of the assessee had escaped assessment. - AT....

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Reassessment u/s 147 challenged due to lack of evidence; reopening based on assumptions, not facts.