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2022 (6) TMI 441 - AT - Income TaxAssessment u/s 153A OR reopening of assessment u/s 147 - as submitted on behalf of the assessee that the assessment order is violative of principle of natural justice and in breach of statutory safeguards - HELD THAT:- The reasons as recorded by the AO has no discussion of the material which was taken in account by the investigation wing. It was considered to be sacrosanct - The statement of Kishori Saran Goel is not part of the reasons to believe nor supplied and confronted to assessee, while issuing notice u/s.148 of the Act. There is force in contention of counsel of assessee that as scrutiny assessment u/s. 153A in regard to assessee was conducted that all the more required to disclose the tangible material in regard to transaction requiring reassessment. There should have been an independent application of mind by the Ld. AO to the information out of the statement forming basis of allegations of accommodation entries. Merely reproducing the conclusions of investigation report in his own words is indeed borrowed satisfaction as contended by counsel for the assessee. Consequently, the Bench is inclined to decide these grounds of cross objection in favour of the assessee. Decided against revenue.
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