Revenue Must Prove Assessee's Disclosure Failures; Pr.CIT's Superficial Approval Under Scrutiny in Tax Case.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Reopening of assessment - The onus lies on the Revenue to point out that there is a failure on the part of the assessee to disclose material facts fully and truly indeed. The onus placed by 1st proviso has been clearly overlooked in the instant case. It is apparent that Pr.CIT has also acted perfunctorily while granting approval sought by AO under the shelter of Section 147(b) as pointed out on behalf of the assessee. - AT....