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In the result, both the appeals by the assessee are allowed
Bench: Shri Chandra Poojari & Smt. Beena Pillai
189 TAXMAN 1 (BOM.), the Hon’ble Bombay High Court held as under:- “For all these reasons, it is evident that there was absolutely no basis for the first respondent to form a belief that any income chargeable to tax has escaped assessment within the meaning of the substantive provisions of section 147. Explanation (2) to section 147 creates