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2014 (7) TMI 174 - HC - Income TaxReassessment u/s 148 of the Act Bar of limitation Held that:- The reasons recorded for issuing the notice specifically points out that commission paid to M/s.Bonas & Co.Ltd. (a foreign party) is not shown separately but added to the cost of purchase while commission paid on local purchase has been separately shown in the profit and loss account and not added to costs - there has been less than full and true disclosure of all material facts during the assessment proceedings for AY 2005-06 - This is for reason that if the commission paid to the foreign party was shown separately as in case of local purchase, the question of tax deduction at source would have become the subject matter of examination by the AO while assessing the Assessee's income during regular assessment. The particular reason for reopening of the Assessment has not been dealt with by the petitioner in its objection to the reasons for reopening the assessment for AY 2005-06 furnished - it cannot be concluded that the notice dated 29.3.2012 is without jurisdiction - there was failure on the part of the assessee to fully disclose all material facts necessary for assessment the reopening of the assessment by notice dated 29.3.2012 as well as the order dated 25.10.2012 rejecting the objections need not be interfered Decided against Assessee.
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