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2014 (4) TMI 212 - BOMBAY HIGH COURTValidity of reassessment proceedings u/s 148 of the Act - Reason to believe as to the income escapement - Held that:- Every aspect of the transaction was not only disclosed but was specifically noticed by the AO -every relevant aspect had been brought to the notice of the AO not merely in the return filed by the assessee but in answer to the specific queries and in response to the requisitions of the AO during the assessment proceedings - No aspect of the matter remained to be disclosed - No aspect of the matter remained to be even sought by the AO - the assessee had not failed to disclose any material relevant to the assessment of its income for the assessment year. Relying upon Rabo India Finance Limited vs. Deputy CIT [2012 (7) TMI 519 - BOMBAY HIGH COURT] - there is nothing on record that indicates that the AO did not consider the material before him – though the nature of the queries raised and the information sought by him indicates that he not only noticed but considered the information supplied by the assessee – thus, it cannot be held that the assessee had failed to disclose fully and truly all material facts necessary for its assessment for the assessment year – Decided in favour of Assessee.
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