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2021 (8) TMI 568 - HC - Income TaxReopening of assessment u/s 147 - no failure on the part of the assessee to disclose fully and truly the details and particulars necessary for completing the assessment u/s 143(3) - HELD THAT:- Reopening of the assessment was after years and there was no tangible material to establish that the assessee failed to disclose fully and truly all materials, which are required for the assessment at the first instance. Tribunal took note of the fact that the assessee has furnished all necessary details required for completing the assessment including the photostat copies of the Sale Deed. Tribunal observed that the original Sale Deed will always be with the buyer of the property and the assessee will have only a certified copy and the AO did not insist upon production of the original Sale Deed while completing the assessment under Section 143(3) - Therefore, it was held that there was no case for reopening the assessment. Tribunal was fully justified in holding that the reopening of the assessment could not have been made in the facts and circumstances of the case and we find no question of law, much less substantial question of law arising for consideration in this appeal.
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