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2023 (7) TMI 347 - HC - Income TaxReopening of assessment u/s 147 - reassessment after the expiry of four (4) years from the end of the relevant AY - reasons to believe - HELD THAT:- A perusal of the reasons furnished by the AO for triggering the reassessment proceeding would show that there is no reference to the fact that the petitioner had failed to disclose, fully and truly, all material facts necessary for carrying out the assessment. Since the proceeding was triggered after the expiry of four (4) years from the end of the relevant AY, the concerned officer, i.e., the ACIT, was required to assert that income chargeable to tax has escaped assessment on account of the failure on the part of the petitioner to disclose truly and fully all material facts necessary for assessment qua the concerned AY, as stipulated in the first proviso appended to Section 147 of the Act. Decided in favour of assessee.
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