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2016 (9) TMI 1644 - AT - Income TaxValidity of reopning of assessment - Reopening beyond period of four years - Disallowance of provision towards warranty expenses and set off of brought forward losses of amalgamating company - HELD THAT:- Reopening of assessment originally completed under section 143(3) by the Assessing Officer after the expiry of four years from the end of the assessment year under consideration without pointing out specifically in the reasons recorded that the income chargeable to tax has escaped assessment by reason of the failure on the part of the assessee to disclose fully and truly all material facts necessary for his assessment is bad in law and the assessment completed under section 143(3)/147 in pursuance thereof is liable to be cancelled on this ground also. We accordingly cancel the assessment made by the Assessing Officer under section 143(3)/147 holding the same as bad in law and allow the Cross Objection filed by the assessee.
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