2021 (8) TMI 835

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..... d under clause (e) of section 2(22) viz. to any concern in which such shareholder is a member or a partner and in which he has substantial interest - HC held in the absence of any failure on the part of the petitioner to disclose fully and truly all material facts necessary for his assessment, the reopening of assessment beyond a period of four years from the relevant assessment is without author .....

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