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2015 (11) TMI 1138 - HC - Income TaxReopening of assessment - Held that:- No whisper of the petitioner having failed to disclose fully and truly all the material facts necessary for its assessment. It is therefore clear that the necessary ingredients for invoking the provisions of Section 147 beyond the period of four years are missing. As such, the initiation of the reassessment proceedings pertaining to the assessment year 2005-06 is without the authority of law. We may also point out that the very issue which has been raised in the reasons has been considered in detail in the course of the original assessment proceedings. In fact, the reasons themselves indicate that what is sought to be done through reassessment was already available in the record of the assessment proceedings. The agreements which have been referred to in the reasons were available before the Assessing Officer and had been examined in detail by the Assessing Officer. Therefore, there is also substance in reopening of assessment - Decided in favour of assessee.
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