Court Rules Reopening of Assessment Invalid u/s 147: No Justifiable "Reason to Believe" for Undisclosed Share Transactions.

Reopening of assessment u/s 147 - Validity of reason to believe - Undisclosed share transactions - It cannot be said that Petitioner did not disclose fully and truly all material facts necessary for the assessment. Consequently, Respondent No. 2 could not have arrived at the satisfaction that he had reasons to believe that income chargeable to tax had escaped assessment. .....

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