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    <title>1976 (7) TMI 11 - ALLAHABAD High Court</title>
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    <description>Assessment for 1950-51 made in 1959 was held time-barred because extension beyond the normal limitation period depended on the statutory concealment framework, and the Tribunal had found that the assessee disclosed the material facts necessary for assessment. Penalty proceedings had also been dropped, so the assessment could not be saved from limitation on that basis. On concealment, the Tribunal found no concealment regarding the receipt in question, treating it as a matter on which an honest difference of opinion was possible as to whether it was a gift or income. Both issues were answered in favour of the assessee.</description>
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    <pubDate>Wed, 07 Jul 1976 00:00:00 +0530</pubDate>
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      <title>1976 (7) TMI 11 - ALLAHABAD High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=38423</link>
      <description>Assessment for 1950-51 made in 1959 was held time-barred because extension beyond the normal limitation period depended on the statutory concealment framework, and the Tribunal had found that the assessee disclosed the material facts necessary for assessment. Penalty proceedings had also been dropped, so the assessment could not be saved from limitation on that basis. On concealment, the Tribunal found no concealment regarding the receipt in question, treating it as a matter on which an honest difference of opinion was possible as to whether it was a gift or income. Both issues were answered in favour of the assessee.</description>
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      <pubDate>Wed, 07 Jul 1976 00:00:00 +0530</pubDate>
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