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    <title>1982 (7) TMI 136 - ITAT CALCUTTA-C</title>
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    <description>Reassessment under section 147(a) was invalid because the assessee had disclosed the primary facts relating to the loan transaction in the original proceedings, and reopening was based only on a different view of the same material. The statutory condition of failure to disclose fully and truly all material facts was therefore not met, so the reassessment was void. The addition of the loan amount as unexplained income also could not stand, as the transaction was supported by account-payee cheques and bank entries, and the disclosed materials did not justify treating it as undisclosed income. The reassessment was annulled and the addition deleted.</description>
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    <pubDate>Fri, 09 Jul 1982 00:00:00 +0530</pubDate>
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      <title>1982 (7) TMI 136 - ITAT CALCUTTA-C</title>
      <link>https://www.taxtmi.com/caselaws?id=60398</link>
      <description>Reassessment under section 147(a) was invalid because the assessee had disclosed the primary facts relating to the loan transaction in the original proceedings, and reopening was based only on a different view of the same material. The statutory condition of failure to disclose fully and truly all material facts was therefore not met, so the reassessment was void. The addition of the loan amount as unexplained income also could not stand, as the transaction was supported by account-payee cheques and bank entries, and the disclosed materials did not justify treating it as undisclosed income. The reassessment was annulled and the addition deleted.</description>
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      <pubDate>Fri, 09 Jul 1982 00:00:00 +0530</pubDate>
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