Court Upholds Assessee's Duty for Full Disclosure in Tax Reassessment; Loan Arguments Insufficient to Avoid Obligation.

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....Reopening of assessment - reason to believe - The Court evaluates the concept of "true and full disclosure" as mandated by Section 147, considering relevant legal precedents. It emphasizes that the duty lies on the assessee to disclose fully and truly all material facts necessary for assessment. The Court finds that the petitioner's submission regarding loan transactions does not negate the necessity for disclosure of material facts, particularly regarding cash transactions. Thus, the Court upholds the respondent's contention regarding lack of full disclosure.....