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2022 (6) TMI 271 - HC - Income TaxReopening of assessment - Validity of notice u/s 148 - assessee obligation to disclose the material facts and such disclosure should be full and true and the petitioner has made true and full disclosure of all material facts - HELD THAT:- As in Phool Chand Bajrang Lal [1993 (7) TMI 1 - SUPREME COURT] had held that the reassessment proceedings may be started either because of some fresh fact come into light which were not previously disclosed or some information with regard to the fact previously disclosed comes into light which intends to expose untruthfulness of those facts. In the present case, the reassessment has been ordered upon discovery of apprehended untruthfulness of facts previously disclosed, and therefore, the judgment in Phool Chand Bajrang Lal (supra) does not support the petitioner and as per the law laid down in Srikrishna [1996 (7) TMI 2 - SUPREME COURT] the reassessment proceedings have rightly been initiated. As already been held by this Court the finding of the Assessing Officer that the petitioner had not made full and true disclosure of all the material facts which relied in an income having escaped assessment is based on reasons which need no interference by this Court in exercise of its jurisdiction under Article 226 of the Constitution of India and we do not find any error apparent on the face of record in the aforesaid finding. The judgment passed by this Court has also been sought to be reviewed on the ground that various case laws relied upon by the petitioner in support of its claim have not been considered by this Court. In the judgment sought to be reviewed, the judgments of Aventis Pharma Ltd. [2010 (3) TMI 317 - BOMBAY HIGH COURT], Arun Gupta. [2015 (2) TMI 213 - ALLAHABAD HIGH COURT] and United Electrical Co. Ltd. [2002 (10) TMI 86 - DELHI HIGH COURT] cited by the learned counsel for the petitioner have been referred to and dealt with. This Court is not obliged to refer to each and every judgment forming part of a compilation of judgments submitted after conclusion of oral submissions, which judgments were not placed before the Court during oral submissions. Moreover, while deciding the writ petition, we have referred to and relied upon the relevant case laws and it is not been submitted by the petitioner that in the judgment sought to be reviewed, the law applicable to the facts of the case has not been taken into consideration. Therefore, this submission also stands rejected.
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