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TMI Blog1984 (1) TMI 85X X X X Extracts X X X X X X X X Extracts X X X X ..... sments for the asst. yrs. 1973-74 and 1974-75 were completed on 30th Jan., 1975 and 30th Dec., 1976 on total incomes of Rs. 18,600 and Rs. 18,230 under s. 143(3). For the asst. yr. 1978-79 the assessment was completed on 14th Nov., 1980 on an income of Rs. 14,220. However, for the asst. yrs. 1973-74 and 1974-75, the assessments were re-opened under s. 147(a) by issuing notices under s. 148, since ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... firm were added to the income of the assessee for the assessment years in question. 3. The assessee, being aggrieved, came up in appeals before the ld. AAC. The ld. AAC upheld the re-opening of the assessments on the ground that the assessee had failed to disclose fully and truly all material facts although there was a specific column in the return of income which obliged the assessee to disclo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ble Allahabad High Court in the case of Sahu Govind Prasad vs. CIT (1984) 34 CTR (All) 297 (FB) : (1983) 144 ITR 851 (All) (FB). In that decision, the Hon'ble Allahabad High Court had also held that the fact that the Hon'ble Supreme Court dismissed the Special Leave Petition of the Department against the decision of CIT vs. Sanka Sankaraiah 1978 CTR (AP) 24 : (1978) 113 ITR 313 (AP) decided by the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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