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2019 (10) TMI 1301 - AT - Income TaxReopening u/s 147 - information received from Office of Pr. Director of Income Tax that Assessee is a beneficiary who contrived loss, who shifted out through client code modification - HELD THAT:- From composite discrepancies recorded in the reasons recorded, it is apparent that the ld AO on receipt of information has not at all looked at the return of income filed by the assessee. Thus, the issue is squarely covered by the decision in PCIT Vs. RMG Polyvinyl (I) Ltd. [2017 (7) TMI 371 - DELHI HIGH COURT]. In this case the specific information such as date of return, amount of income returned and whether the escapement of income is provided or loss has not at all been verified by the ld AO. In view of this on the above reasons recorded by the ld AO, we do not upheld the reassessment proceedings initiated by the ld AO thus, on the issue of reopening u/s 147 we reverse the finding of the lower authorities and allow ground 1 of the appeal of assessee.
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