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2015 (7) TMI 1422 - MADRAS HIGH COURTReopening of assessment u/s 147 - Disallowance of broken period interest - Whether Tribunal was right in holding that the reopening of assessment was not proper ? - HELD THAT:- There is a specific finding of the Tribunal that re-openings were done after the end of four years from the assessment years in question and, therefore, the first proviso to Section 147 will squarely apply and it is required for the Revenue to show that there was failure on the part of the assessee to disclose fully and truly material facts necessary for the assessment. Therefore, in those appeals the Tribunal was in favour of the assessee.
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