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2011 (1) TMI 1037 - HC - Income TaxReopening of assessment - beyond a period of four years from the end of the relevant assessment year - Held that:- No failure on the part of the petitioner to disclose fully and truly all material facts necessary for its assessment for the assessment year under consideration, facts of the present case would stand squarely covered by the decision of this court in the case of CIT v. Bipin Vadilal (1999 (4) TMI 77 - GUJARAT High Court) inasmuch as the belief as to escapement of income chargeable to tax from assessment was not entertained by the Assessing Officer on the ground that there had been failure on the part of the assessee to disclose fully and truly all material facts necessary for the assessment and as such, no proceedings could have been initiated under section 148 after the expiry of a period of four years from the end of the relevant assessment year, assessment barred by limitation, assumption of jurisdiction by the Assessing Officer itself is invalid, petition succeeds and is accordingly allowed.
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