Section 147 Reopening Flawed: AO Misinterprets Facts, Incorrectly Applies Section 68 on Nonexistent Credit Entries.

Reopening of assessment u/s 147 - addition on account of unsecured loan from 3 parties - AO has reopened the assessment based upon wrong facts, wrong appreciation of facts and without any application of any mind, in as much as, the assessee has not taken any credit entry but, in fact, have made debit entries and, therefore, by no stretch of imagination provisions of section 68 of the Act can be applied. - AT .....

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