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    <title>2006 (3) TMI 102 - KERALA High Court</title>
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    <description>The court concluded that the assessee was not justified in claiming the deduction for penal interest as the liability did not accrue in the relevant assessment year. The failure to disclose this material fact justified the reopening of the assessment, and the notice under section 148 was valid even after the expiry of four years. The appeal by the Revenue was allowed, the order of the Tribunal was set aside, and the questions of law were answered in favor of the Revenue and against the assessee.</description>
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      <description>The court concluded that the assessee was not justified in claiming the deduction for penal interest as the liability did not accrue in the relevant assessment year. The failure to disclose this material fact justified the reopening of the assessment, and the notice under section 148 was valid even after the expiry of four years. The appeal by the Revenue was allowed, the order of the Tribunal was set aside, and the questions of law were answered in favor of the Revenue and against the assessee.</description>
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