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Assessee has raised the ground thatthe CIT (Appeals) failed to appreciate that there was absolutely no 'reason to believe' on the escapement of income in the recording of reasons while assuming jurisdiction u/s 147 of the Act and consequently ought to have appreciated that the consequential framing of the re-assessment was wrong, incorrect, unjustified, erroneous and not sustainable both on facts and in law.

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Sec. 147 of Income Tax Act, 1961— Reassessment—SHRI K. SRIKANTH vs. Asstt. CIt.[2020] 25 ITCD Online 047 (ITAT-CHENNAI)