Court Upholds CIT (A)'s Decision: Reopening of Assessment u/s 147 for Protective Addition Deemed Unjustified.

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....Reopening of assessment u/s 147 - protective addition - Neither at the time of recording the reasons, nor at the time of framing the assessment, AO was’nt sure about whose income has escaped assessment. We do not find any reason to interefere with the findings of the CIT (A) that reopening for resorting to make protective assessment cannot be upheld - AT....