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2014 (3) TMI 180 - AT - Income TaxValidity of Assessment - Escapement of income – Assessment reopened within four years – Particulars not furnished – Held that:- The order of the CIT(A) is not correct on the facts of the case as the proviso to section 147 can only be invoked in a case where the assessment has been reopened after the end of four years from the end of the A.Y - the assessment under section 143(3) has been done in this case - the assessment has been reopened before the end of four years from the A.Y., this proviso will not apply - The order of the CIT(A) was not correct on the given facts of the case – thus, without going into the other merits of the assessee’s contentions, the objections of the Revenue is upheld - the order of the CIT(A) set aside – the matter remitted back to the CIT(A) for fresh consideration – Decided in favour of Revenue.
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