Court Upholds Reopening of Assessment u/s 147 Due to Incomplete Disclosure, Rejects Sole Legal Question Argument.

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....Reopening of assessment u/s 147 - Unexplained cash deposits - we are unable to accept the submission made on behalf of the petitioner that presumptive income is purely a question of law and has to be decided as per provisions contained in Section 44 AD and 44 BBB. As we have already held that the petitioner had failed to disclose fully and truly all material facts necessary for the assessment, the bar of four years would not apply. - HC....