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TMI Blog2016 (10) TMI 1364X X X X Extracts X X X X X X X X Extracts X X X X ..... ssment? - HELD THAT:- The reasons, as recorded merely indicate that there was client code modification which lead to a non genuine loss. The reasons do not indicate, how the aforesaid facts led to the AO having reason to believe that income chargeable to tax has escaped assessment. Therefore, prima facie there is absence of link between information obtained and escapement of income chargeable to t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rn was processed under Section 143(1) of the Act. The reasons in support of the impugned notice reads as under : "In this case the assesse had filed return of income on 25.07.2011 declaring total income of Rs.89,840/and the same was processed u/s.143(1). The case was not selected for scrutiny assessment for the year under consideration. As per information dissipated by the Assistant Director o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... this case in terms of the provisions of section 147 of the I.T. Act." 3. The challenge in this petition is on the ground that the reasons as recorded do not indicate any reason to believe that income chargeable to tax has escaped assessment. The reasons, as recorded hereinabove, merely indicate that there was client code modification which lead to a non genuine loss. The reasons do not indicate, ..... X X X X Extracts X X X X X X X X Extracts X X X X
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