In the result, appeal filed by the assessee is allowed
Bench: Shri V. Durga Rao & Shri K.M. Roy, Accountant, Member
reassessment is general in nature and is not on specific transaction of assessee. Evidence placed on record is not found to be incorrect or false. Conclusion of escapement of income tantamount to mere change of opinion. Belief of escapement of income could not be derived on the basis of report of Investigation Wing being not specific to transaction of loan