TMI Blog2019 (2) TMI 1330X X X X Extracts X X X X X X X X Extracts X X X X ..... s escaped assessment. As further pointed out that in this case the impugned notice has been issued on 31st March, 2018 in relation to AY 2011-12 which is clearly beyond a period of four years from the end of the relevant assessment year without there being any failure on the part of the petitioner to disclose fully and truly all material facts necessary for his assessment, therefore, the assumptio ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... en the assessment on the ground that the firm had claimed excess deduction of ₹ 57,71,499/- under Section 10AA of the Income Tax Act, 1961 which was liable to be taxed in the hands of the partners. It was pointed out that in that case the court has issued notice and has restrained the respondents from passing the final order. 2. Referring to the reasons recorded, it was submitted that in ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... not have formed the belief that income chargeable to tax has escaped assessment. It was further pointed out that in this case the impugned notice has been issued on 31st March, 2018 in relation to Assessment Year 2011-12 which is clearly beyond a period of four years from the end of the relevant assessment year without there being any failure on the part of the petitioner to disclose fully and tr ..... X X X X Extracts X X X X X X X X Extracts X X X X
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