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    <title>2018 (12) TMI 189 - ITAT DELHI</title>
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    <description>The Tribunal held that the assumption of jurisdiction under Section 147 of the Income Tax Act was not justified as the necessary condition for reopening beyond four years was not met. The Tribunal quashed the reopening proceedings, emphasizing that income escaped assessment due to the assessee&#039;s failure to disclose material facts, which was not alleged by the Assessing Officer. Additionally, the Tribunal found that the addition of Rs. 3,01,69,142 for unverified purchases was made without securing any new material and without proving any failure to disclose material facts. As a result, the Tribunal allowed the appeal of the assessee, pronouncing the order on 31/10/2018.</description>
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      <title>2018 (12) TMI 189 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=371420</link>
      <description>The Tribunal held that the assumption of jurisdiction under Section 147 of the Income Tax Act was not justified as the necessary condition for reopening beyond four years was not met. The Tribunal quashed the reopening proceedings, emphasizing that income escaped assessment due to the assessee&#039;s failure to disclose material facts, which was not alleged by the Assessing Officer. Additionally, the Tribunal found that the addition of Rs. 3,01,69,142 for unverified purchases was made without securing any new material and without proving any failure to disclose material facts. As a result, the Tribunal allowed the appeal of the assessee, pronouncing the order on 31/10/2018.</description>
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