2023 (9) TMI 1043

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..... H COURT] notice u/s 148 is to be issued after expiry of four years or before expiry of six years, the assessee should have failed to disclose the material facts and on consideration of the material on record has held that AO has not even stated or alleged that there was failure on the part of assessee to disclose fully and truly all the material facts necessary for the said assessment years - H .....

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