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In the result, the appeal for Asstt
Bench: Sh. Manoj Kumar Aggarwal & Sh. Udayan Dasgupta
10 I.T.A. Nos. 346 & 347/Asr/2024 Assessment Years: 2014-15 & 2015-16 inducing the belief. Such a belief has not to be based on mere suspicion but it must be based on information as was held by Hon'ble Supreme Court in the case of Calcutta Discount Co. Ltd. Vs. ITO 41 ITR 191. Thus, initiation of proceedings u/s 147 cannot