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2014 (12) TMI 764 - DELHI HIGH COURTReassessment held as invalid u/s 147 by Tribunal - Investment reflected in the books of accounts of M/s Ishwar Dass Sahni & Brothers Ltd. or not – Held that:- The reason for issuing notice u/s 148 was not as the revenue is contending - queries with regard to investment were raised by the AO and reply and submissions were made by the assessee - the Tribunal has also recorded that the records of the AO were incomplete and some papers were missing - the assessee had disclosed the factum of investment of ₹ 1,66,23,750/- The finding of the Tribunal is that the assessee had made this disclosure at the time of original assessment by responding to question asked from assessee – the issue is a factual matter and there is no need to interfere in the order of the Tribunal – Decided against revenue.
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