Reassessment of Late EPF Contributions u/s 148 Challenged; No New Facts Presented by AO, Initial Disclosure Sufficient.

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....Reassessment u/s 148 - EPF not paid within time as per section 2(24)(x) r.w.s 36(1)(va) - duly disclosed in TAR and allowed in assessment - no new fact is brought on record by the AO and nor there is any failure on part of the petitioner to disclose fully and truly all material facts necessary for assessment - as per First Proviso to section 147, AO cannot assume jurisdiction.....