Court Upholds Reopening of Tax Assessment for Unexplained Gift u/s 147; Validates Administrative Process.

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....Reopening of assessment u/s 147 - Unexplained gift receipt - “reason to suspect” or “reasons to believe” - The relevance of the reasons for the formation of the belief is to be tested by the judicial restraint as in administrative action as the Court does not sit as a Court of appeal but merely reviews the manner in which the decision was made. The Court shall not examine the sufficiency or adequacy thereof. - no infirmity in the processing of reopening u/s 148 - AT....