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    <title>1992 (7) TMI 26 - CALCUTTA High Court</title>
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    <description>Reassessment initiated beyond four years from the end of the assessment year could be sustained only if the assessee had failed to disclose fully and truly all material facts necessary for assessment under section 147. The reopening was based on a later finding in the assessee&#039;s son&#039;s case that he was a benamidar, but that finding arose long after the original assessment and was not in existence when the assessee was assessed. A fact not then in existence could not be treated as material that the assessee was bound to disclose. The reassessment was therefore held not validly initiated, and the reference was answered in favour of the assessee.</description>
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    <pubDate>Thu, 23 Jul 1992 00:00:00 +0530</pubDate>
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      <title>1992 (7) TMI 26 - CALCUTTA High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=20711</link>
      <description>Reassessment initiated beyond four years from the end of the assessment year could be sustained only if the assessee had failed to disclose fully and truly all material facts necessary for assessment under section 147. The reopening was based on a later finding in the assessee&#039;s son&#039;s case that he was a benamidar, but that finding arose long after the original assessment and was not in existence when the assessee was assessed. A fact not then in existence could not be treated as material that the assessee was bound to disclose. The reassessment was therefore held not validly initiated, and the reference was answered in favour of the assessee.</description>
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      <pubDate>Thu, 23 Jul 1992 00:00:00 +0530</pubDate>
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