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TMI Blog1979 (4) TMI 94X X X X Extracts X X X X X X X X Extracts X X X X ..... herefore proceed to dispose of this appeal after hearing the Departmental Representative. 2. In this departmental appeal, the only point that is agitated is that the AAC erred in cancelling the reassessment made under s. 147A of the IT Act, 1961 for the asst. yr. 1970-71. The accounting year relevant for the asst. yr. 1970-71 ended on 31st March, 1970. The original assessment on the assessee was ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ITR 335). The AAC further referred to Supreme Court ruling in 100 ITR 1. He observed that the information regarding the remodelling of the house during the periods relevant for the asst. yrs. 1969-70 and 1970-71 as well as the amounts expended on such remodelling was within the knowledge of the ITO from the seized materials as early as 13th Aug., 1971 when the original assessment was completed onl ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... uld have discovered material evidence with due diligence would not necessarily amount to disclosure within the meaning of the section. He also referred to the ruling of the Madras High Court in the case of K.P. Arthanariswamy Chettiar & Others vs. First ITO, Circle I, Salem (1). He pointed out that the disclosure should not only be full but also be true. 5. On a careful consideration of the submi ..... X X X X Extracts X X X X X X X X Extracts X X X X
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