Reopening of assessment for non-existent and factually incorrect reasons was invalid

Shri Ram Mohan Rawat Vs ITO (ITAT Jaipur)

Reasons recorded by the AO for formation of belief that income assessable to tax has escaped assessment are based on two counts. One, the assessee has made bogus purchases and the second, that the purchases are not verifiable as the as the  assessee has not filed the return of income. Thus the formation of belief is based on these two factual aspects that the assessee has made bogus purchases which are not verifiable as assessee has not filed the return of income. The reaso

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