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2014 (4) TMI 1152 - HC - Income TaxReopening of assessment - Held that:- The appellant had disclosed all primary facts before the A.O. at the time of original assessment and there was no omission or failure on the part of the appellant to disclose fully and truly all material facts necessary for assessment. Therefore in view of the above the proceedings initiated under Section 147 cannot be justified and accordingly treated as invalid and void ab-initio. Exercise under Section 148 of the I.T. Act was started after expiry of four years from the end of the relevant assessment years, the department was obliged to demonstrate that the assessee had failed "to disclose fully and truly all material facts necessary for his assessment, for that assessment year which was not done - Decided against revenue
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