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The grievance of the assessee is twofold. Firstly, the assessee is aggrieved by the action of the CIT(A) to uphold the proceedings initiated u/s 148 of the Act as valid and lawful proceedings and secondly, the assessee is aggrieved by the addition of Rs.46,05,594/- made by the AO to the returned income of the assessee.

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Sec. 147 & 148 of Income Tax Act, 1961—Reassessment— The recording of reasons to believe and not reasons to suspect is the pre- condition to the assumption of jurisdiction under Section 147 and reasons to believe must demonstrate link between the tangible material and the formation of the belief or the reason to believe that income has escaped assessment - MAGAN BEHARI LAL V/s DEPUTY CIT - [2019] 75 ITR (TRIB) 322 (ITAT-DELHI)

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