Assessment Reopening u/s 147 Needs More Than Excel Extracts; Third-Party Entries Insufficient for Unexplained Investments.

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....Reopening of assessment u/s 147 - Merely extracts of excel sheet do not provide any evidence of the allegation made by the AO against the assessee. Thus, mere fact that there were certain entries found from record of third party is not sufficient to make addition on the ground that assessee had made unexplained investments. - AT....