Appellate Tribunal Cannot Overturn CIT(A) Decision Without Justification on Full Disclosure by Assessee.

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....Reopening of assessment u/s 147 - The CIT(A) recorded a finding of fact that there was no failure on the part of the assessee to disclose fully and truly all the material facts necessary for the assessment. Such finding of fact could not have been disturbed by the appellate tribunal without any basis for the same.....