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High Court Rules Against Reopening Tax Assessment After Four Years Due to Lack of New Evidence u/s 147.

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....Reopening of assessment u/s 147 - Notice after the expiry of 4 years - reliance on self-same material - Respondent revenue could not establish in course of hearing that there was any omission or failure on the part of the assessee petitioner in disclosing truly and fully any material fact necessary for the assessment before the Assessing Officer in course of scrutiny assessment. - HC....