2021 (11) TMI 712

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....llowing question of law :- "1. Whether on the facts and in the circumstances of the case and in law, the Hon'ble Tribunal erred in quashing the reassessment proceeding after 4 years on the ground that there was no failure on the part of assessee to disclose all material facts when it is apparent from records that it was never disclosed as to how the interest of Rs. 3,07,25,000/- received fro....

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....the Appeal by its order dated 10/08/2016. The ITAT held that there was no new material or failure on the part of Respondent to disclose truly and fully material facts in order to reopen the assessment beyond 4 years. Aggrieved by this order, this Appeal is preferred. 3. If one considers the order of the CIT(A) as well as the order of the AO, the admitted position is that Respondent has disclosed ....

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....sonal balance-sheet and income and expenditure account filed along with returns under Section 139(1) of the Act contain entries relating to this amount of Rs. 3,07,25,000/- received as interest on Tax Free Bonds. The AO had also raised a query in this regard and the Assessee has given proper explanation before the AO and after considering the explanation, the earlier assessment order was passed un....