TMI Blog1989 (2) TMI 97X X X X Extracts X X X X X X X X Extracts X X X X ..... ts giving rise to this petition, briefly, are as follows: For the assessment year 1981-82, the petitioner-firm had filed a return disclosing income of Rs. 1,25,000. The petitioner-firm had also furnished details of payment of interest and also details of interest received on fixed deposits. The Income-tax Officer framed the assessment by his order dated March, 21, 1984, and the total income of the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... be dismissed. Before we proceed to appreciate the contentions urged on behalf of the parties, it will be useful to reproduce the order (annexure R-1) passed by the respondent recording reasons for reopening the assessment. The order is as follows : "During the course of assessment proceedings for the assessment year 1982-83, it has been noticed that the assessee-firm has not disclosed the a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... capement is by reason of the omission or failure on the part of the assessee to make a return or to disclose fully and truly all material facts necessary for his assessment for the relevant year. It is also well-settled that the expression "material facts" used in clause (a) of section 147 of the Act refers only to primary facts. Now, in the instant case, it is not disputed that the assessee had d ..... X X X X Extracts X X X X X X X X Extracts X X X X
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