Assessee's Incomplete Documentation Justifies Reopening of Assessment u/s 147; No Entitlement to Proviso Protections.

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....Reopening of assessment u/s 147 - it seems to us that during the original assessment proceedings, the assessee has not submitted entire books of accounts, bills, vouchers, bank statements, purchases/sales vouchers, details of direct and indirect expenses incurred by assessee and other necessary evidences to disclose fully and truly all material facts necessary for making original assessment, therefore, assessee cannot take the benefit of proviso to section 147 - AT....