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    <title>1980 (2) TMI 21 - CALCUTTA High Court</title>
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    <description>Reopening of assessment under section 147(a) of the Income-tax Act was upheld where the assessee had already failed to dislodge the finding that there was no full and true disclosure of material facts. The High Court noted that the reopening issue had earlier been decided against the assessee in writ proceedings, and the Tribunal had acted on that basis in refusing reference under section 256(1). Applying CIT v. Lakhiram Ramdas, the Court held that no direction under section 256(2) could be made because the assessee had not mounted an appropriate challenge to the basic factual finding. The authorities cited by the assessee were distinguished on facts, and the application was rejected.</description>
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    <pubDate>Tue, 12 Feb 1980 00:00:00 +0530</pubDate>
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      <title>1980 (2) TMI 21 - CALCUTTA High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=36354</link>
      <description>Reopening of assessment under section 147(a) of the Income-tax Act was upheld where the assessee had already failed to dislodge the finding that there was no full and true disclosure of material facts. The High Court noted that the reopening issue had earlier been decided against the assessee in writ proceedings, and the Tribunal had acted on that basis in refusing reference under section 256(1). Applying CIT v. Lakhiram Ramdas, the Court held that no direction under section 256(2) could be made because the assessee had not mounted an appropriate challenge to the basic factual finding. The authorities cited by the assessee were distinguished on facts, and the application was rejected.</description>
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      <pubDate>Tue, 12 Feb 1980 00:00:00 +0530</pubDate>
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