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2020 (11) TMI 170 - AT - Income TaxReopening of assessment u/s 147 - Unexplained addition u/s 68 - HELD THAT:- As a regular assessment and the Assessing Officer had nowhere recorded the assessee’s failure in having disclosed fully and truly, all the relevant particulars, sec. 147 first proviso restricting the exercise of the re-opening jurisdiction without satisfying the corresponding embargo, renders the same as not sustainable in the eyes of law. We quote hon'ble apex court’s celebrated decision in K.Y. Pillah And Sons [1966 (10) TMI 35 - SUPREME COURT] to affirm the CIT(A)’s action quashing the impugned re-opening in entirety as their lordships made it clear long back that such a course of actors may not involve independent examination of the relevant facts at the tribunal’s behest.- Decided against revenue.
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