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Reopening of assessment u/s 147 - reason to suspect v/s reason to believe - The reasons disclosed and...

Reopening of assessment u/s 147 - reason to suspect v/s reason to believe - The reasons disclosed and placed on record do not allude to the material that was available to the AO which persuaded him to form a belief that income in the concerned AY, pertaining to SGCPL, which was otherwise chargeable to tax, had escaped assessment. - The reasons did not advert to the material that was available to him and which persuaded him to form a belief that income chargeable to tax had escaped assessment. - HC .....

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