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2007 (2) TMI 167 - PUNJAB AND HARYANA HIGH COURTReopening of the assessment u/s 148 - reasons were recorded by competent authority for initiation of reassessment proceedings - not successfully argued that the reasons did not have any nexus with the material available with AO - nothing on record to show the relationship between donor & donee - assessee failed to discharge onus to prove gifts - it is against the human probability that a stranger is claimed to have made gifts – reassessment proceedings were valid – assessee’s appeal dismissed
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