2020 (2) TMI 1338

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....ER S. Jayaraman,  The assessee filed this appeal against the order of the Commissioner of Income Tax (Appeals)-7, Chennai in ITA No. 99(t)/CIT(A)-7/2017-18 dated 25.01.2019 for assessment year 2009-10. 2. Shri. B. Suresh Kumar, the assessee, director of M/s. S&S Enterprises is engaging in providing end to end liaison service to various multinational companies and corporate clients engage....

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....om the end of the assessment year 2009-10, the AO issued a notice u/s. 148 dated 25.01.2016. In such case, in accordance with first proviso to section 147, the officer should have recorded the reason of failure on the part of the assessee to disclose fully and truly all material facts necessary for his assessment in that assessment year. In this case, there is no fresh material and there is no fai....