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Notice Set Aside: AO's Non-Utilization of Gathered Materials Doesn't Equal Assessee's Failure to Disclose u/s 147.
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....Reassessment u/s 147 - Department had collected certain documents and materials in search which were before the AO at the time of framing assessment - non utilization of such material by AO for any reason cannot be considered as failure to disclose truly and fully all material facts by assessee - impugned notice is set aside....