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    <title>1970 (4) TMI 3 - Supreme Court</title>
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    <description>Reassessment under section 34(1)(a) of the Income-tax Act, 1922 cannot be sustained where the Income-tax Officer already had knowledge of the primary facts and seeks to reopen the assessment merely by changing his view on the same material. The second notice and the reassessment founded on it were therefore invalid because the reopening was not based on any failure by the assessee to make a full and true disclosure of primary facts, and the result was in favour of the assessee.</description>
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      <description>Reassessment under section 34(1)(a) of the Income-tax Act, 1922 cannot be sustained where the Income-tax Officer already had knowledge of the primary facts and seeks to reopen the assessment merely by changing his view on the same material. The second notice and the reassessment founded on it were therefore invalid because the reopening was not based on any failure by the assessee to make a full and true disclosure of primary facts, and the result was in favour of the assessee.</description>
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      <pubDate>Thu, 16 Apr 1970 00:00:00 +0530</pubDate>
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