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of Reopening of assessment u/s 147 - What was the term of the contract under which the revenue was generated or the bill raised on a client or a customer cannot be certified in the Audited Profit and Loss Account and the Balance Sheet. At best, they can corroborate what is there in the contract. Therefore, unless those supporting documents are produced, it cannot be said that there was full disclosure. - No justifiable reasons to interfere at this stage of the re-assessment proceedings. - HC
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