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2012 (5) TMI 337 - HC - Income TaxReassessment - notice u/s 148 - ceased liability - deemed income u/s 41(1) - held that:- it can be easily seen that both the issues were within the knowledge of the Assessing Officer while original assessment was being framed. Not only that the assessee had disclosed all facts pertaining to these issue but had made further clarifications in response to the queries raised by the Assessing Officer. Thus, it cannot be said that there was failure on the part of the assessee to truly and fully disclose all material facts. In the present case, therefore, when the assessment is sought to be reopened beyond the period of four years from the end of the relevant assessment year, the same would not be permissible.
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