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1979 (4) TMI 42 - ITAT CALCUTTAExtract: .......der s. 147(a) and s. 148 of the Act. All these cases, therefore, fall in the ratio of 103 ITR 437(SC). In the present case, facts establishing any such direct nexus between the material and the formation of the belief by the ITO are absent and the reassessment proceedings cannot, therefore, be upheld as validly initiated. 15. The appeal is allowed.
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