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1999 (2) TMI 16 - SC - Income Tax
There is, therefore, no failure on the part of the assessee to disclose fully and truly the material facts necessary for the assessment years for the respective years and as such section 147(a) has no manner of application and is not attracted in the facts of the matter under consideration - held that the question as regards reopening of the assessment under section 147(a) of the Act would not arise further