Assessment Reopening and Addition Justified: AO Had "Reason to Believe" Based on Sections 133(6) and 131 Inquiries.

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....Reopening of assessment u/s 147 - addition u/s 68 - Reason to believe - It cannot be said that there was no basis that the AO to frame “reason to believe” and in such situation it cannot be said that the ld. AO has issued notice u/s 148 upon the assessee as void-ab-initio. Since the ld. AO had made instant enquiry u/s 133(6) and u/s 131 of the Act from the directors of the companies, from where share premium was received by the assessee company and he discovered that assessee company had rooted its own fund/unaccounted money through the shareholders company - CIT(A) is wrong in treating the notice issued u/s 148 AO was void-ab-initio - AT....