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    <title>1984 (5) TMI 69 - ITAT BOMBAY-C</title>
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    <description>Reassessment under section 147(a) was invalid because the assessee had disclosed the primary material facts, including the bungalow construction, expenditure, payment statements, bank accounts and sources of investment. The assessee was not required to state the inferences the assessing authority should draw, and omission of minute details such as quantity of materials used did not amount to failure to disclose fully and truly all material facts. The assessing authority could have made further inquiry or referred the matter for valuation but did not do so, and an already available survey report could not justify reopening for the later year. The additions in reassessment were therefore not sustainable.</description>
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    <pubDate>Tue, 22 May 1984 00:00:00 +0530</pubDate>
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      <title>1984 (5) TMI 69 - ITAT BOMBAY-C</title>
      <link>https://www.taxtmi.com/caselaws?id=58694</link>
      <description>Reassessment under section 147(a) was invalid because the assessee had disclosed the primary material facts, including the bungalow construction, expenditure, payment statements, bank accounts and sources of investment. The assessee was not required to state the inferences the assessing authority should draw, and omission of minute details such as quantity of materials used did not amount to failure to disclose fully and truly all material facts. The assessing authority could have made further inquiry or referred the matter for valuation but did not do so, and an already available survey report could not justify reopening for the later year. The additions in reassessment were therefore not sustainable.</description>
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      <pubDate>Tue, 22 May 1984 00:00:00 +0530</pubDate>
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