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2014 (8) TMI 764 - AT - Income TaxReopening of assessment u/s 147 Full and true disclosure not made by assessee Held that:- The FAA had noticed certain discrepancies in the reassessment proceedings, so, he had directed the AO to send his comments - the AO did not comply with his directions and in spite of getting more than one opportunity he did not submit his comments to the FAA, so, that he could take an informed decision - the FAA was left with no alternative but to decide the matter on merits - From January to July 2012, the AO did not send his report to a judicial authority for the reasons best known to him only - FAA is very senior officer of the department and entrusted with a responsibility of carrying out judicial work Non-cooperation with him is not only beyond our comprehension but also against the departmental discipline - The matter does not end here only. When the FAA decides the appeal on merits the same AO challenges it alleging that the FAA has erred - The chronology of events prove in unequivocal terms that if somebody had erred it was the AO and not the FAA - He has tried to improve upon his case lately in form of grounds of appeal filed before us the order of the FAA should have been accepted gracefully and the administrative approval should not have been given to file the second appeal - thus, the order of the FAA does not suffer from any legal or factual infirmity Decided against revenue.
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