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Revenue has raised the ground that on the facts and in the circumstances of thecase, the ld. CIT (A) has erred in deleting addition of Rs. 12,74,04,995/- made by AO u/s 68 on account of accommodation entry taken by the assessee without appreciating the facts discussed in the assessment order.

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Sec. 147 of Income Tax Act, 1961— Reassessment — AO must disclose in the reasons as to which fact or material was not disclosed by the assessee fully and truly necessary for assessment of that assessment year, so as to establish vital link between the reasons and evidence and that vital link is the safeguard against arbitrary reopening of the concluded assessment and the reasons recorded by the Assessing Officer cannot be supplemented by filing affidavit or making oral submission, otherwise, the reasons which were lacking in the material particulars would get supplemented, by the time the matter reaches to the Court, on the strength of affidavit or oral submissions advanced- Notice issued under section 147 itself is beyond the period of four years from the end of the assessment year 1996-97 and does not comply with the requirements of proviso to section 147, the Assessing Officer had no jurisdiction to reopen the assessment proceedings which were concluded on the basis of assessment under section 143(3). - ASSTT. CIT V/s SHIV VEGPRO PVT. LTD. - [2020] 82 ITR (TRIB) 195 (ITAT-JAIPUR)