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    <title>1980 (5) TMI 54 - ITAT BOMBAY-C</title>
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    <description>Reassessment under section 147(a) cannot be based on a supposed failure to disclose material facts where the assessee has already furnished the primary details in the original proceedings. Here, the hundi loan particulars were disclosed, and the assessing officer had the material before him, including sufficient basis to pursue further enquiry into genuineness. The defect lay in the officer&#039;s failure to investigate, not in any suppression by the assessee. On that principle, reopening was invalid and the reassessment was cancelled in favour of the assessee.</description>
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    <pubDate>Thu, 08 May 1980 00:00:00 +0530</pubDate>
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      <description>Reassessment under section 147(a) cannot be based on a supposed failure to disclose material facts where the assessee has already furnished the primary details in the original proceedings. Here, the hundi loan particulars were disclosed, and the assessing officer had the material before him, including sufficient basis to pursue further enquiry into genuineness. The defect lay in the officer&#039;s failure to investigate, not in any suppression by the assessee. On that principle, reopening was invalid and the reassessment was cancelled in favour of the assessee.</description>
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