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    <title>2018 (12) TMI 1217 - MADRAS HIGH COURT</title>
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    <description>The court held that the reopening of the assessment under section 147 was invalid as there was no failure by the assessee to disclose all material facts. Consequently, the court found that the reassessment based on the same facts previously considered during the original assessment was impermissible. The appeal was allowed in favor of the assessee, and the substantial questions of law were decided against the Revenue.</description>
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      <description>The court held that the reopening of the assessment under section 147 was invalid as there was no failure by the assessee to disclose all material facts. Consequently, the court found that the reassessment based on the same facts previously considered during the original assessment was impermissible. The appeal was allowed in favor of the assessee, and the substantial questions of law were decided against the Revenue.</description>
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