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2021 (4) TMI 383 - AT - Income TaxReopening of assessment u/s 147 - re-opening of assessment was beyond four years from end of assessment year - HELD THAT:- Admittedly, the re-opening of assessment is after the expiry of four years from the end of assessment year 2008-09 and hence the proviso to Section 147 of the Act comes into play. A reading of the reasons recorded for re-opening of assessment shows that there is no allegation made, that there is failure on the part of the assessee to truly and fully disclose material facts necessary for the assessment. Under these circumstances, we have to hold that the re-opening of assessment is bad in law. Thus we hold that the re-opening is bad in law. In the result, the impugned assessment order is hereby quashed.
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