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2011 (11) TMI 365 - HC - Income TaxRE-opening of Income escaping assessment after 4 years from relevant A/Y- Deduction under 80HHC were allowed without allowing deduction under 80IB - Held That:- All material facts were available on record and no material facts had to be inferred or discovered by the assessing officer. failure to apply law or a section to admitted facts on record is not covered by Explanation (1). When assessee had disclosed all the relevant facts AO could not issue notice under 148 after 4 years.
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