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2017 (6) TMI 1151 - AT - Income TaxReopening of assessment - interest income from FDR - Held that:- We find that in the instant case the Assessing Officer completed the reassessment first time on 22/12/2006 and there is no change in the facts of the interest income from FDR, reopening of the reassessment dated 22/12/2006, amounts to change of opinion and which is not permitted by law. In the instant assessment year, the first reassessment was completed under section 147 of the Act and four years had expired from the end of the relevant assessment year on 31/03/2007, therefore, the reassessment completed on 22/12/2006 could not have been reopened after 31/03/2007 except in the event of failure by the assessee in disclosing fully and truly all material facts. The Assessing Officer in the reasons recorded has not pointed out any such failure on the part of the assessee in disclosing material facts. Thus invoking the provision of section 147 second time reassessment could not have been made in the case of the assessee. - Decided in favour of assessee.
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