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    <title>1979 (11) TMI 148 - ITAT MADRAS-B</title>
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    <description>Reassessment under section 147(a) was held unjustified where the assessee had disclosed the house construction in the return and the Department relied only on alleged under-valuation of the construction cost. The fact of construction was not treated as a material fact requiring separate disclosure in the absence of a specific query during assessment. Even if material, disclosure in Part III of the return was regarded as sufficient. A mere difference between the amount disclosed and the later estimate by the Income-tax Officer did not establish failure to make a full and true disclosure of material facts; the duty to investigate the correct cost lay with the assessing authority.</description>
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    <pubDate>Tue, 06 Nov 1979 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=69771</link>
      <description>Reassessment under section 147(a) was held unjustified where the assessee had disclosed the house construction in the return and the Department relied only on alleged under-valuation of the construction cost. The fact of construction was not treated as a material fact requiring separate disclosure in the absence of a specific query during assessment. Even if material, disclosure in Part III of the return was regarded as sufficient. A mere difference between the amount disclosed and the later estimate by the Income-tax Officer did not establish failure to make a full and true disclosure of material facts; the duty to investigate the correct cost lay with the assessing authority.</description>
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