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2016 (4) TMI 1369 - AT - Income TaxReopening of assessment u/s 147 - case reopened after four years - HELD THAT:- Re-opening notice was admittedly beyond a period of four years. It is also an undisputed position that reasons recorded for reopening of an assessment does not mention any failure on the part of the Respondent to disclose fully and truly all material facts necessary for the assessment. As decided in TITANOR COMPONENTS LTD. VERSUS ACIT, CIT AND UOI [2011 (6) TMI 138 - BOMBAY HIGH COURT] it is necessary for the AO to first observe that there is a failure to discloser fully and truly all material facts necessary for assessment and having observed that there is such failure to proceed under Section 147 - no substantial question of law - decided against revenue
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