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2022 (4) TMI 796 - AT - Income TaxValidity of reopening of assessment u/s 147 - Eligibility of reasons to believe - HELD THAT:- AO has not alleged that there is a failure on the part of the assessee to disclose fully and truly all material facts to complete the assessment. That apart, we find that there is no failure on the part of the assessee in respect of disclosure of all relevant materials required for assessment fully and truly. Therefore, in our opinion, the reopening of assessment under section 147 of the Act is invalid and the same is quashed.
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