2006 (11) TMI 188

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....owing question of law has been referred for the opinion of this court by the Income-tax Appellate Tribunal, Delhi Bench "C", Delhi, arising out of its order dated January 30, 1990, in I. T. A. No. 1034/Delhi of 1988 in respect of the assessment year 1979-80:  "Whether, on the facts and in the circumstances of the case, the Income-tax Appellate Tribunal is right in law in annulling the asse....

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....oke jurisdiction under section 147/148 of the Income-tax Act, 1961. Reliance was placed on a judgment of the hon'ble Supreme Court in Kalyanji Mavji and Co. v. CIT [1976] 102 ITR 287. 3. We have heard learned counsel for the Revenue and perused the record. 4. We are of the view that the decision taken by the Tribunal is in accordance with the law laid down by the hon'ble Supreme Court and th....

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....ieve that, by reason of omission or failure on the part of the assessee to make a true and full disclosure of all material facts necessary for his assessment during the concluded assessment proceedings, any part of his income, profits or gains chargeable to income-tax had escaped assessment. He may start reassessment proceedings either because some fresh facts had come to light which were not prev....