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2017 (1) TMI 847 - HC - Income TaxValidity of reopening of assessment - reasons to believe - Held that:- We find that both the CIT(A) as well as the Tribunal have on facts held that all facts necessary for assessment were truly and fully disclosed by the respondent assessee for the subject assessment year during the assessment proceedings. In fact, even the basis of the present proceedings i.e. the reasons recorded in support of the notice does not support, even remotely, any submission to allege failure on the part of the respondent assessee to truly and fully disclose all necessary facts for assessment. Therefore, as correctly held by the CIT(A) and the Tribunal, the reopening notice dated 24th September, 2003 would be hit by the proviso to Section 147 of the Act.
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