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2019 (5) TMI 1774 - AT - Income TaxReopening of assessment u/s 147 - period of limitation - reopening of beyond the period of four years - HELD THAT:- When the return of income was revised for the purpose of claiming the deduction for provision of bad and doubtful debts, how can thereafter it be said that the assessee failed to disclose the fact of deduction being claimed for provision of bad debts. In the reasons recorded also, the Assessing Officer has not been able to point out how there is failure on the part of the assessee to disclose fully and truly all material facts. There was no failure on the part of the assessee to disclose fully and truly all material facts which has resulted in escapement of income and therefore, as per proviso to Section 147, the assessment cannot be reopened beyond the period of four years. The same is barred by limitation. No failure on the part of the assessee to disclose fully and truly all material facts and the original assessment having been completed under Section 143(3), the notice under Section 148 beyond the period of four years is barred by limitation. The same is quashed. - Decided in favour of assessee.
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