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2013 (9) TMI 977 - HC - Income TaxValidity of issue of Notice u/s 148 to assess the income escaped assessment – Held that:- No any material was discovered by A.O, prior to issuing notice under Section 148 nor any such material was discovered from any other source, which may have given him reason to believe that the income has escaped income. The A.O. based his findings on the same material, which were disclosed in the return after making some more enquiries and which was not permissible as the limitation of 4 years had expired - Not only primary evidence but all details and documents were before the A.O. and that it was obvious that no discrepancies or defects have been noted by the AO in respect of such details/ documents - Contention of the AO that the shares of the companies, which were private limited were not traceable in the stock exchange did not have conclusive evidentially value – Decided against the Revenue.
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