https://www.taxtmi.com/highlights?id=73130 Reopening of assessment - The onus lies on the Revenue to point out that there is a failure on the part of the assessee to disclose material facts fully and truly indeed. The onus placed by 1st proviso has been clearly overlooked in the instant case. It is apparent that Pr.CIT has also acted perfunctorily while granting approval sought by AO under the shelter of Section 147(b) as pointed out on behalf of the assessee. - AT en-us Tue, 21 Nov 2023 08:32:19 +0530 Tue, 21 Nov 2023 08:32:19 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=73130 Reopening of assessment - The onus lies on the Revenue to point out that there is a failure on the part of the assessee to disclose material facts fully and truly indeed. The onus placed by 1st proviso has been clearly overlooked in the instant case. It is apparent that Pr.CIT has also acted perfunctorily while granting approval sought by AO under the shelter of Section 147(b) as pointed out on behalf of the assessee. - AT Highlights Income Tax Tue, 21 Nov 2023 08:32:19 +0530 https://www.taxtmi.com/highlights?id=73130