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2013 (3) TMI 411 - HC - Income TaxReassessment - Period of Limitation - sec. 147 - Held that :- The Tribunal without giving any finding on the controversy, simply declared that the notice for reopening which was issued beyond four years was barred by limitation.It was possible for the Tribunal to examine the facts on record and to come to a conclusion that the CIT [A] was incorrect in holding. The Tribunal committed grave error in declaring the notice of reopening invalid without coming to the conclusion that CIT [A] had erred in holding that there was failure on the part of the assessee to truly and fully disclose the facts necessary for assessment Appeal of the Revenue is restored to the Tribunal for fresh consideration - decided n favor of revenue.
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