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2022 (7) TMI 1213 - AT - Income TaxValidity of reopening of assessment u/s 147 - notice beyond four years from the end of the relevant assessment year - HELD THAT:- From the perusal of the reasons, it is evident that the ld. AO had not applied the proviso to Section 147 of the Act by indicating in the reasons as to whether there was any failure on the part of the assessee to make full and true disclosure of facts that are material for the purpose of assessment. Hence, the reopening proceedings deserve to be quashed on this count also. Thus the re-assessment proceedings are hereby quashed. Since the re-assessment proceedings are quashed on legal ground, the other grounds raised by the assessee on merits need not be adjudicated.
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