Reopening Assessment Ruled Invalid Due to Lack of 'Reason to Believe' in Share Premium Allegations.

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....Validity of reopening of assessment - ‘reason to believe’ v/s 'reason to suspect' - allegation of issue of shares on premium to paper companies - Since AO has not carried out even the preliminary enquiry after taking note of assessee collecting share capital with premium, the AO cannot be said to be possessing the requisite reason to believe, escapement of income. - AT....