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A perusal of the appraisal report, on which reliance has been placed by the Assessing Officer, reveals that there was sufficient material for the Assessing Officer to form the belief that income chargeable to tax has escaped assessment. The material also specifically refers to the petitioner, which clearly establishes a link between the relied upon materials and the petitioner. Considering the nature of material available with the Revenue, it is not possible to state that on the reasons recorded, the Assessing Officer could not have formed the belief that income chargeable to tax has escaped assessment.

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Section 147 & 148 of the Income Tax Act, 1961 — Reassessment — Material which formed the basis for the formation of belief that income chargeable to tax had escaped assessment was the evidence found during the course of search and the appraisal report which revealed that there was sufficient material for the AO to form the belief that income chargeable to tax had escaped assessment, thus, reassessment prcoceedings were valid— Purnima Konalkant Sharma vs. Deputy Commissioner of income tax [2019] 419 ITR 361(Gujarat)

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