TMI Blog2022 (8) TMI 1314X X X X Extracts X X X X X X X X Extracts X X X X ..... sing all the relevant particulars. Faced with this situation, we quote section 147 (1st proviso) and hon ble jurisdictional high court s landmark decision in Hindustan Lever Ltd. vs. R. B. Wadkar [ 2004 (2) TMI 41 - BOMBAY HIGH COURT] to quash the impugned reopening for this precise reason alone. Decided in favour of assessee. - ITA No.1765/PUN/2019 - - - Dated:- 25-8-2022 - SHRI S.S. GODARA, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... .12.2011 followed by his section 148 notice dated 27.03.2015. Mr. Jasnani could hardly rebut the clinching fact that the same reopening reason nowhere indicated that the assessee s taxable income had escaped assessment on account of it s failure in fully and truly disclosing all the relevant particulars. Faced with this situation, I quote section 147 (1st proviso) and hon ble jurisdictional hi ..... X X X X Extracts X X X X X X X X Extracts X X X X
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