TMI Blog2007 (8) TMI 726X X X X Extracts X X X X X X X X Extracts X X X X ..... 25.11.1997 issued under Section 148 of the Income Tax Act, 1961. The assessment was completed under Section 143(3) on 25.03.1991. The assessment year is 199091. In the assessment, the claim of the assessee under Section 80HH and 80I has been allowed. Thereafter, notice dated 25.11.1997 has been issued for reopening of the assessment and following reasons have been recorded before issuing the n ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 24/u/ s.80I. Thus, the assessee has furnished inaccurate particulars of income in so far as income from trading was shown as income from Industrial Undertaking. Thus, I have reason to believe that income chargeable to tax has escaped assessment for A.Y.9091 because of omission and failure on the part of the assessee to disclose income truly and fully. The car is covered by explanation 2(c) o ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ction 80HH, but relevant material was there before the assessing officer to disallow the claim, if he has wrongly claimed the deduction. When the material facts were before the assessing officer at the time of assessment, there is no justification to issue notice under Section 148 of the Act, after expiry of four years from the end of assessment year. Notice dated 25.11.1997 under Section 14 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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