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2021 (8) TMI 456 - AT - Income TaxReopening of assessment u/s 147 - HELD THAT:- There should be a failure on the part of the Assessee to disclose fully and truly all the material facts necessary for that assessment for that particular assessment year. In this case, the reasons recorded clearly indicates that, there is no such finding recorded by the Assessing Officer for the reopening of the assessment. Considering the proviso to Section 147 of the Act and also by following in the case of Commissioner of Income Tax and Another Vs. Foramer France [2000 (8) TMI 45 - ALLAHABAD HIGH COURT] and in the case of Fenner (India) Limited Vs. Deputy Commissioner of Income Tax [1998 (11) TMI 66 - MADRAS HIGH COURT], we hold that the reopening is not valid. - Decided in favour of assessee.
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