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2006 (3) TMI 102 - KERALA HIGH COURTReopening of the assessment under section 143(3) read with section 147 - notice under section 148 after the expiry of four years from the end of the assessment year - This is a case where the assessee has got an undue benefit which it should not have got since it was following the mercantile system of accounting. The assessee had disclosed certain materials and on the basis of the same the assessee got some benefit which it should not have got. - contention of the assessee that no substantial question of law arises for consideration is rejected. The questions of law raised are substantial questions of law. The questions referred to us are answered in favour of the Revenue – Held that there was failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment justifying reopening of assessment - Assessing Officer was justified in issuing notice under section 148 after the expiry of four years
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