Reopening of Tax Assessment Invalid u/s 147 Due to Lack of Legitimate Basis and Insufficient Evidence.

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....Reopening of assessment u/s 147 - Validity of reasons to believe - No linkage of the assessee has been established with the information received from investigation wing and the reopening is based merely on borrowed satisfaction. The reasons were mere reasons to suspect and not the reasons to believe that the income had escaped assessment. This being the case, the reopening could not be held to be valid in the eyes of law - AT....