Reopening Assessment u/s 147 on Partnership Deed's Validity Doesn't Breach Section 184; Needs Further Verification.

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....Reopening of assessment u/s 147 - genuineness of partnership deed - No contravention of s. 184 due to non- signing of the front pages of the partnership deed by the partners so as to attract s.185. The Revenue is only making a guess in view of the long time interval between possible date of execution (as stated in the deed itself), i.e., 1.4.2007, and the date of its notarization; rather, admitting that the matter needs to be examined and ascertained. That is, there is a reason to suspect, and not a reason to believe for want of the relevant information. - AT....