Court Rules Against Reopening Assessment u/s 147 Due to Lack of Evidence and Substantiation by Assessing Officer.

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....Reopening of assessment u/s 147 - AO did not rebut the appellant’s contention that nothing over and above the amount recorded in the registered sale deeds was received by bringing necessary details. The unsubstantiated material found in the diary in possession of Third Party cannot be considered in the hands of the assessee as a conclusive evidence so as to reopen the assessment and make additions towards long term capital gain in sale of the plot of land. - AT....