Assessment Reopening Invalid: AO Failed Minimal Investigation on Rs. 23.40 Crore Unsecured Loans u/s 147, CIT(A) Quashes Notice.

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....Validity of reopening of assessment u/s 147 - AO has not even made minimum exercise for ascertaining the unsecured loans accepted during the year, under consideration before reopening of the assessment. Without even ascertaining the unsecured loans accepted during the year in the reasons recorded, the AO viewed that the entire sum of ₹ 23.40 crores outstanding as per the balance sheet was suspicious and escaped from the assessment chargeable to tax. Thus, the above facts clearly show that the AO reopened the assessment only with a suspicion without having sufficient reasons to form the belief for escapement of income - CIT(A) has rightly quashed the notice - AT....