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    <title>2014 (10) TMI 6 - ALLAHABAD HIGH COURT</title>
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    <description>The High Court upheld the Tribunal&#039;s decision that the initiation of proceedings under Section 148 of the Income Tax Act was barred by limitation. The Court found that the notice issued beyond four years did not mention the failure of the assessee to disclose all material facts necessary for assessment, rendering it invalid. The Court emphasized the requirement for the Income Tax Officer to have a valid reason to believe that income had escaped assessment due to the assessee&#039;s failure to disclose material facts. As a result, the appeal filed by the Department was dismissed in favor of the assessee.</description>
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    <pubDate>Tue, 23 Sep 2014 00:00:00 +0530</pubDate>
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      <title>2014 (10) TMI 6 - ALLAHABAD HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=251872</link>
      <description>The High Court upheld the Tribunal&#039;s decision that the initiation of proceedings under Section 148 of the Income Tax Act was barred by limitation. The Court found that the notice issued beyond four years did not mention the failure of the assessee to disclose all material facts necessary for assessment, rendering it invalid. The Court emphasized the requirement for the Income Tax Officer to have a valid reason to believe that income had escaped assessment due to the assessee&#039;s failure to disclose material facts. As a result, the appeal filed by the Department was dismissed in favor of the assessee.</description>
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      <pubDate>Tue, 23 Sep 2014 00:00:00 +0530</pubDate>
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