1979 (4) TMI 94

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..... r hearing the Departmental Representative. 2. In this departmental appeal, the only point that is agitated is that the AAC erred in cancelling the reassessment made under s. 147A of the IT Act, 1961 for the asst. yr. 1970-71. The accounting year relevant for the asst. yr. 1970-71 ended on 31st March, 1970. The original assessment on the assessee was completed on 28th March, 1973 under s. 143(3) .....

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..... Court ruling in 100 ITR 1. He observed that the information regarding the remodelling of the house during the periods relevant for the asst. yrs. 1969-70 and 1970-71 as well as the amounts expended on such remodelling was within the knowledge of the ITO from the seized materials as early as 13th Aug., 1971 when the original assessment was completed only on 28th March, 1973. The AAC further observe .....

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..... e diligence would not necessarily amount to disclosure within the meaning of the section. He also referred to the ruling of the Madras High Court in the case of K.P. Arthanariswamy Chettiar Others vs. First ITO, Circle I, Salem (1). He pointed out that the disclosure should not only be full but also be true. 5. On a careful consideration of the submissions made before us and on a perusal of th .....

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