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2005 (1) TMI 344 - ITAT JODHPURExtract: ....... 769 (Raj). So far as the other reason is concerned, this loan was accepted as genuine by the AO himself. So, this reason does not survive. So in my opinion, there was no valid reason for the reopening to form a reasonable belief to issue notice under s. 148 of the Act. 7. In the result, I uphold the findings of the CIT(A) and I dismiss the appeal.
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