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Reopening Assessments: Substance Over Form in Recorded Reasons for Escaped Long-Term Capital Gains.
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....Reopening of assessment - bogus long-term capital gain has escaped assessment - Scope of the reasons recorded by the AO - The reasons are to be seen in its substance. If there is some error in mentioning some information which is not so fatal, then, on trivial matters, the reasons recorded cannot be held to be invalid or nonapplication of mind cannot be inferred. - AT....