To invoke sec. 147 AO has to prove that Assessee Escaped Income

Priyank Mittal Vs. ITO (ITAT Agra)

A perusal of the reasons recorded by the AO shows that the allegation as per the reasons to believe escapement of income is bogus purchase/sale of shares, while the impugned addition has been made with respect to gift, which shows that the A.O. had no specific information. Hence, as rightly contended, the reasons recorded are vague and farfetched. The A.O., vide letter date 01.12.2009 (Paper Book Pg.16) alleged that the appellant had entered into the transaction of sale/purch

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