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2020 (10) TMI 554 - AT - Income TaxValidity of reopening of assessment u/s 147 - information received from the Investigation Wing - reopening a completed assessment after four years - assessee has received share application money from accommodation entry providers - HELD THAT:- Specific query was raised in respect of share application money and vide reply assessee furnished all details as required by the Assessing Officer. Pursuant to the reply of the assessee and on perusal of the details, the Assessing Officer issued notice u/s 133(6) of the Act to the three share applicant companies. Not only these companies complied with the notices received u/s 133(6) of the Act from the Assessing Officer, but all of them filed confirmations, confirming the transactions along with bank statements and copies of Income Tax returns. No hesitation to hold that the observation of the Assessing Officer that the share applicant companies are non-est is without any basis. Original assessment was completed after due verification from share applicant companies and share applicant companies have been assessed to tax u/s 153C read with section 153A of the Act post search and post enquiries made by the Assessing Officer. Considering the totality of the facts of the case in hand, we find that reopening is nothing but change of opinion when every aspect was examined in the original assessment proceedings - Decided in favour of assessee.
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