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    <title>2025 (11) TMI 1678 - GUJARAT HIGH COURT</title>
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    <description>HC upheld the validity of reassessment proceedings initiated under section 147 against the assessee. It held that the assessee failed to fully and truly disclose all material facts necessary for assessment, as the agreement with the Central Government-critical for claiming deduction under section 42-was not produced during the original assessment. Mere disclosure of the deduction claim in the audit report and return was held insufficient where the statute predicates deduction on the terms of such agreement. Accepting the concurrent factual findings of the AO, CIT(A) and Tribunal, the HC found no perversity and ruled that income had escaped assessment due to the assessee&#039;s omission. The appeal was dismissed and the matter decided against the assessee.</description>
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    <pubDate>Thu, 13 Nov 2025 00:00:00 +0530</pubDate>
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      <title>2025 (11) TMI 1678 - GUJARAT HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=782210</link>
      <description>HC upheld the validity of reassessment proceedings initiated under section 147 against the assessee. It held that the assessee failed to fully and truly disclose all material facts necessary for assessment, as the agreement with the Central Government-critical for claiming deduction under section 42-was not produced during the original assessment. Mere disclosure of the deduction claim in the audit report and return was held insufficient where the statute predicates deduction on the terms of such agreement. Accepting the concurrent factual findings of the AO, CIT(A) and Tribunal, the HC found no perversity and ruled that income had escaped assessment due to the assessee&#039;s omission. The appeal was dismissed and the matter decided against the assessee.</description>
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      <pubDate>Thu, 13 Nov 2025 00:00:00 +0530</pubDate>
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