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2017 (1) TMI 1750 - AT - Income TaxReopening of assessment u/s 147 - Reopening after expiry of a period of four years from the end of the relevant assessment year - assessee has not filed relevant details - HELD THAT:- Assessee admittedly filed the Profit & Loss account and other details which are required for completing the assessment. Therefore, it cannot be said that there was any negligence on the part of the assessee. Merely because the Assessing Officer could not examine the Profit & Loss account filed by the assessee in the course of regular assessment, that cannot be a reason to say that the assessee has not filed relevant details. This Tribunal is of the considered opinion that when the assessee provided all the relevant details before the Assessing Officer and the Assessing Officer has also completed assessment under Section 143(3) of the Act, it cannot be said that there was any negligence on the part of the assessee. Therefore, reopening of assessment beyond the period of four years from the end of the relevant assessment year is outside the scope of Section 147 of the Act. In view of the above, this Tribunal do not find any reason to interfere with the order of the lower authority and accordingly the same is confirmed. Appeal filed by the Revenue is dismissed.
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