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    <title>1977 (10) TMI 55 - ITAT DELHI-A</title>
    <link>https://www.taxtmi.com/caselaws?id=63076</link>
    <description>The appeal challenged the addition of Rs. 20,000 as undisclosed income under section 147(a) of the IT Act, 1961. The court found that all material facts were disclosed during the original assessment, and the ITO&#039;s failure to draw correct inferences did not justify invoking section 147(a). As the action was time-barred, the assessment was set aside, emphasizing that section 147(a) was inapplicable due to the absence of failure to disclose necessary particulars by the assessee. The appeal was allowed, and the judgment did not analyze legal cases or the case&#039;s merits beyond the disclosure issue.</description>
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    <pubDate>Wed, 05 Oct 1977 00:00:00 +0530</pubDate>
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      <title>1977 (10) TMI 55 - ITAT DELHI-A</title>
      <link>https://www.taxtmi.com/caselaws?id=63076</link>
      <description>The appeal challenged the addition of Rs. 20,000 as undisclosed income under section 147(a) of the IT Act, 1961. The court found that all material facts were disclosed during the original assessment, and the ITO&#039;s failure to draw correct inferences did not justify invoking section 147(a). As the action was time-barred, the assessment was set aside, emphasizing that section 147(a) was inapplicable due to the absence of failure to disclose necessary particulars by the assessee. The appeal was allowed, and the judgment did not analyze legal cases or the case&#039;s merits beyond the disclosure issue.</description>
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      <pubDate>Wed, 05 Oct 1977 00:00:00 +0530</pubDate>
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