2014 (9) TMI 206

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....the assessment year 2005-2006. In the present case, original assessment order was passed under Section 143(3) on 13th March, 2007. Subsequently, the reassessment proceedings were initiated by issue of notice under Section 148 read with Section 147 of the Income Tax Act, 1961 ('Act' for short) on the ground that the respondent/assessee had declared exempt income of Rs. 1,49,30,835/- by w....

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....s invalid as the assessing officer in the first/original round was aware of full details and figures of exempt income as well as taxable income. The assessing officer in the reasons to believe or the assessment order had not observed that the assessee had not disclosed full and true material particulars. The Tribunal has affirmed the said finding. In the present case, the reassessment procee....

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....o his failure to disclose full and true material facts. In the present case, full facts were in the knowledge and known to the assessing officer. Explanation to Section 147 of the Act would not be applicable. Neither was the said explanation invoked as the details were per se available and apparent. Factually nothing was to be deciphered or culled out. Possibly the assessing officer felt that no e....