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    <title>2015 (4) TMI 761 - ITAT CHENNAI</title>
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    <description>Reassessment beyond four years after a scrutiny assessment under section 143(3) requires a demonstrable failure by the assessee to disclose fully and truly all material facts, and it was held invalid for the years where that condition was absent; reopening was sustained where the recorded material showed a proper basis to believe income had been wrongly classified and losses had been set off. Interest received after cessation of NBFC activity and without proof of a continuing money-lending business was treated as income from other sources, not business income. The disallowance under section 14A read with Rule 8D(2)(iii) was also upheld on the basis of all relevant investments.</description>
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      <description>Reassessment beyond four years after a scrutiny assessment under section 143(3) requires a demonstrable failure by the assessee to disclose fully and truly all material facts, and it was held invalid for the years where that condition was absent; reopening was sustained where the recorded material showed a proper basis to believe income had been wrongly classified and losses had been set off. Interest received after cessation of NBFC activity and without proof of a continuing money-lending business was treated as income from other sources, not business income. The disallowance under section 14A read with Rule 8D(2)(iii) was also upheld on the basis of all relevant investments.</description>
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