TMI Blog2021 (11) TMI 712X X X X Extracts X X X X X X X X Extracts X X X X ..... th returns u/s 139(1) of the Act contain entries relating to this amount received as interest on Tax Free Bonds. AO had also raised a query in this regard and the Assessee has given proper explanation before the AO and after considering the explanation, the earlier assessment order was passed u/s 143(3) - ITAT has concluded and it is quite evident by considering the order passed by the AO and CIT(A) that there was no new material in the hands of the assessing authority or there was any lapse on the part of the Assessee to disclose material facts before the assessing authority. CIT(A), in his order, states that the Appellant has failed to disclose fully and truly as to how the interest income is not exempt in the hands of the investor ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nds of the Estate of EF Dinshaw, will also be tax free on distribution to assessee by virtue of the said immunity of the scheme ? 2. For AY 2005-06, the assessment under Section 143(3) of the Income Tax Act, 1961 (hereinafter referred to as 'the Act') was completed on 31/12/2007 computing total income of ₹ 31,77,09,780/-. Subsequently the case was reopened under Section 147 by issuing notice under Section 148 and an order dated 22/12/2011 came to be passed by the Assessing Officer. This order was impugned by Respondent before the CIT(A). The Appeal was dismissed by an order dated 23/09/2013. Aggrieved by this order, Respondent preferred an Appeal before the Income Tax Appellate Tribunal (hereinafter referred to as 'IT ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... in this regard and the Assessee has given proper explanation before the AO and after considering the explanation, the earlier assessment order was passed under Section 143(3) of the Act. The ITAT has concluded and it is quite evident by considering the order passed by the AO and CIT(A) that there was no new material in the hands of the assessing authority or there was any lapse on the part of the Assessee to disclose material facts before the assessing authority. In fact, the CIT(A), in his order, states that the Appellant has failed to disclose fully and truly as to how the interest income of ₹ 3,07,25,000/- is not exempt in the hands of the investor and as to how the exemption of interest has been granted by the legislature in the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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