Reopening of assessment u/s 147 - reason to believe - the reassessment proceedings were triggered...

Reopening of assessment u/s 147 - reason to believe - the reassessment proceedings were triggered without the AO applying his own mind and articulating his reasons as to why he believed that the material available with him was indicative of the fact that the income which was otherwise chargeable to tax had escaped assessment. As correctly submitted, in law reasons to suspect are markedly different in quality and texture from reasons to believe. - HC .....

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