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TMI Blog2013 (10) TMI 312X X X X Extracts X X X X X X X X Extracts X X X X ..... her submitted in return or accompanying documents and not in the documents submitted during the course of the assessment, despite the specific query of A.O. for the same - Held that:- two authorities i.e. CIT(A) and the Tribunal have come to a concurrent finding of fact that all material facts necessary for assessment have been disclosed by the assessee during the course of original proceedings. T ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the assessment, despite the specific query of A.O. for the same? (b) Whether on the facts and in the circumstances of the case and in law the Tribunal was justified in holding the reopening of the case u/s. 147 of the Income-tax Act, after four years is bad in law relying on the documents not submitted during the course of the regular assessment proceedings for that assessment year and for ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... thus there was a failure to disclose all material facts. 3. The Tribunal by the impugned order has upheld the finding of the CIT (Appeals) that all facts with regard to allotment of shares to M/s. Daimler Benz in consideration of technical know-how was disclosed by the assessee to the Assessing Officer by its letter dated 20/3/1995 during the course of assessment. In fact the Tribunal records a ..... X X X X Extracts X X X X X X X X Extracts X X X X
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