https://www.taxtmi.com/caselaws?id=356291 The Tribunal upheld the Commissioner of Income Tax (Appeals) decision, stating that the Assessee's obligation is to disclose all primary facts truly and fully, not legal inferences. The Revenue's contention that the Assessee should have drawn attention to Section 79 during regular assessment was dismissed as the regular Assessment Order was passed under Section 143(3), and the reopening notice was beyond the prescribed period. Failure to apply Section 79 in the regular assessment was not seen as a failure to disclose all necessary material facts. The appeal was dismissed with no order as to costs. en-us Mon, 29 Jan 2018 00:00:00 +0530 Wed, 28 Feb 2018 06:31:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=356291 The Tribunal upheld the Commissioner of Income Tax (Appeals) decision, stating that the Assessee's obligation is to disclose all primary facts truly and fully, not legal inferences. The Revenue's contention that the Assessee should have drawn attention to Section 79 during regular assessment was dismissed as the regular Assessment Order was passed under Section 143(3), and the reopening notice was beyond the prescribed period. Failure to apply Section 79 in the regular assessment was not seen as a failure to disclose all necessary material facts. The appeal was dismissed with no order as to costs. Case-Laws Income Tax Mon, 29 Jan 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=356291