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Appellant's activities fully documented; no malafide intent found. Revenue's extended action period not applicable.

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Full Text of the Document

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....BAS - All the activities undertaken by the appellant were a part of the reflection made in the balance sheet and income tax return in which case no suppression or malafide can be attributed to the assessee. No malafides could be proved by Revenue - the extended period would not be available to the Revenue. - AT....