Reopening of Assessment u/s 147 on Fund Layering Deemed Invalid; Conditions of First Proviso Not Met.

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....Validity of Reopening of assessment u/s 147 - n transaction of layering of funds through the bank account - As is evident from the record the amount due from these entities pertains to the previous financial year and assessee being an Indian company has already paid the taxes thereon, since it follows the mercantile system of accounting. Therefore, we are of the considered view that conditions laid down in 1st proviso to section 147 of the Act are not satisfied in the present case. - AT....