Reopening of assessment u/s 147 - since the proposed re-opening has been issued after expiry of four...

Reopening of assessment u/s 147 - since the proposed re-opening has been issued after expiry of four years of the end of the relevant assessment year, proviso to Section 147 of the Act would apply in as much as the Revenue has to show that there has been fault on the part of petitioner to truly and fully disclose material facts required for assessment. Not only as Revenue not made any such allegations in the reasons for re-opening, we cannot even cull out from the reasons recorded that Revenue h..... .....

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