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2018 (3) TMI 1161 - HC - Income TaxReopening of assessment - assessee had not returned the income received as interest from deposits in Banks - Held that:- In the present case, true, after regular assessment and after notice for reassessment was issued, there was a Supreme Court judgment finding the interest income received even before the commencement of production would be income from other sources. But, that decision is not the cause for the aforesaid reopening. It is only in the assessment order as seen from Annexure-A that the Assessing Officer relied on the decision of the Hon'ble Supreme Court, to further sustain the re-assessment of undisclosed income to tax. The Assessing Officer, later to the regular assessment, saw from the P&L account that there was further income by way of interest from deposits, which had not been disclosed in the returns filed by the assessee. This was the reason for issuance of notice of reassessment, for bringing to tax income that escaped assessment within the six year period. The limitation of 4 years would not be applicable, since the specific allegation, which we have found to be correct, is of non-disclosure of full and true material facts necessary for assessment. We answer the question of law in favour of the Revenue and against the assessee.
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