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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.

Shanti Prime Publication Pvt. Ltd.

Sec. 147 of Income Tax Act, 1961— Reassessment — The reasons recorded by the Assessing Officer nowhere state that there was failure on the part of the assessee to disclose fully and truly all material facts necessary for the assessment of that assessment year and it is needless to mention that the reasons are required to be read as they were recorded by the Assessing Office and no substitution or deletion is permissible - The reasons recorded should be clear and unambiguous and should not suffer from any vagueness and the reasons recorded must disclose his mind and should be self-explanatory and should not keep the assessee guessing for the reasons - Reasons provide link between conclusion and evidence and the Assessing Officer, in the event of challenge to the reasons, must be able to justify the same based on material available on record - - ASSTT. CIT V/s SHIV VEGPRO PVT. LTD. - [2020] 27 ITCD Online 064 (ITAT-JAIPUR)