2013 (10) TMI 312

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....r. ORDER:- In this appeal by the revenue for Assessment Year 1995-96 following questions have been raised for our consideration.      (a) Whether on the facts and the circumstances of the case and in law the Tribunal was justified in holding that there was no failure on the part of the assessee to disclose fully and truly all material facts for his assessment when the ....

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....on 148 of the Act was issued on 26/3/2002 beyond the period of four years from the end of the relevant assessment year. The basis for reopening the assessment was alleged failure on the part of the respondent assessee to disclose the facts with regard to shares being allotted to M/s. Daimler Benz in consideration of technical know-how provided by them. Thus resulting in excess benefit of Section 3....