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2018 (11) TMI 1737 - AT - Income TaxReopening of assessment u/s 147 - reopening beyond 4 years - re-opening on the basis of audit objection - HELD THAT:- There is no new material based on which the Assessing Officer has confirmed the information that income subject to tax has escaped assessment. There is no whisper in the reasons recorded that there was failure on part of the assessee to truly and fully disclose all the material facts required for assessment. When there is no such mention, the Hon’ble Delhi High Court in the case of M/s. Haryana Archylic Manufacturing Company vs. CIT [2008 (11) TMI 2 - DELHI HIGH COURT] , has held to be the re-opening to be bad in law. - Decided in favour of assessee.
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