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Grounds of appeal 1-assessee has challenged reopening of the assessment. 2-assessee has challenged the addition of Rs. 56,43,084/– made by the learned assessing officer on account of the sale consideration on sale of equity shares under section 68 of The Income Tax Act.

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Sec. 147 of Income Tax Act, 1961— Reassessment — When the assessee has provided the complete information, which would have been available with the assessee in the documentary format, the role of the assessing officer starts as an investigator of the information furnished by the assessee, when he recorded the reason, he formed a prima facie reason to believe that there is an escapement of income and he should have converted his reason into the fact by making an investigation on the information provided by the assessee and for the reasons best known to the assessing officer, he did not do anything on the information provided by the assessee and he merely made the addition holding that assessee has not shown justification for purchase of shares at a very high price., therefore, in these circumstances, the addition in the hands of the assessee is not sustainable when the details furnished by the assessee were not at all controverted by bringing cogent material and investigation made thereon by the AO.[2020] 26 ITCD Online 120 (ITAT-DELHI)