2022 (4) TMI 1497

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....h Kumar. ORDER P.C. 1] We find that order passed by respondent No.1 to the objections filed by petitioner does not display application of mind. In the order dated 21.04.2021, at paragraphs 3 and 4, Officer has referred to provisions of sections 149 and 151 of the Act and says why they are applicable, even though no objection has been raised by petitioner regarding its applicability. Moreo....

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....h a person could have relied upon to form a requisite belief is totally incorrect. The Assessing Officer who wishes to reopen after four years from the end of relevant assessment year is duty bound to make out a case of failure to disclose material facts truly and fully by assessee. Therefore, we quash and set aside two orders on objections dated 21.04.2021 and 22.04.2021. 4] We have to also no....