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2016 (6) TMI 43 - AT - Income TaxReopening of assessment - whether the notice is barred by limitation? - Held that:- The undisputed fact is that the notice u/s. 148 was issued beyond the period of four years from the end of the Assessment Year in all the three cases. On the perusal of reasons recorded which are extracted hereinafter, we find that there is no whisper or an allegation that the assessee failed to make a full and true disclosure of all material fact necessary for assessment in its return of income. Thus assessee having fully and truly disclosed all the material facts necessary for the assessment as required by the AO, the precondition for invoking the proviso to s. 147 was not satisfied and therefore, AO acted wholly without jurisdiction in issuing notice under s. 148 beyond the four year period mentioned in s. 147. Thus reopning is bad - Decided in favour of assessee
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