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2019 (10) TMI 389 - AT - Income TaxReopening of assessment u/s 147 - non disclosure of full and true facts - HELD THAT:- As during the course of scrutiny assessment proceedings the books of account were examined and test checked. In light of these facts, coming back to the reasons recorded for reopening of the assessment as mentioned elsewhere, it can be seen that the AO has borrowed the information received from the Director [INV] and on the basis of this information, he had reason to belief that income has escaped assessment and it is a fit case for reopening. Considering the facts of the case in totality, in light of the judicial decisions discussed hereinabove and keeping in mind the first proviso to section 147 of the Act, we are of the considered view that the notice issued u/s 148 of the Act is without jurisdiction and deserves to be set aside.
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