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2009 (9) TMI 613 - AT - Income TaxChange of Opinion - reassessment – Whether CIT(A) erred in deleting the addition on account of investment ill purchase of stock and credit entry arrived at during the course of survey proceedings and post - survey proceedings ignoring the fact that the assessee failed to get it verified by holding that the addition was made solely and exclusively on the basis of loose papers - Books of account and other documents including loose papers pertaining to the year under consideration were found and impounded - impounded books contain cash book, ledger, journal, Gadda nook, debit and credit vouchers, loose papers, gate register, press register, stock register, purchase and sale bills which were test checked - It was, held in CIT vs. Eicher Ltd. (2007 -TMI - 2063 - HIGH COURT , DELHI) that if the AO while passing original assessment order, chose not to give any finding in this regard that could not give him or his successor in office a reason to reopen the assessment of the assessee or to contend that because the facts were not considered in the assessment order a full and true disclosure was not made - reassessment was not permissible – Revenue’s appeal dismissed
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