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“material facts necessary for assessment”

ReassessmentSection 147Section 147564 judgments

The decision most relied on for material facts necessary for assessment is Calcutta Discount Co. Ltd. v. ITO (41 ITR 191), cited in 384 judgments on BharatTax.

Leading authorities on material facts necessary for assessment

Calcutta Discount Co. Ltd. v. ITO
41 ITR 191 · 1961 · Supreme Court
384
citing judgments

The assessee's duty is limited to disclosing all primary, material facts necessary for assessment, including entries, documents, and other evidence. It is for the Assessing Officer to draw inferences of fact and law, and the assessee is not obligated to offer such inferences.

CIT v. Foramer France
264 ITR 566 · 2003 · Supreme Court
253
citing judgments

Reassessment proceedings initiated under Section 147 beyond four years from the end of the relevant assessment year are invalid unless the assessee failed to disclose fully and truly all material facts necessary for assessment. Without such failure, the notice issued under Section 148 is time-barred and without jurisdiction.

153 (Gujarat) 8 Shakti Karnawat v. ITO
296 ITR 90 · 2008 · High Court
171
citing judgments

A live link of third-party information can form the basis for reopening an assessment under Section 148, provided it contains material facts necessary for assessment. The Assessing Officer must demonstrate a "reason to believe" that income has escaped assessment, which can be satisfied by such information even if it pertains to other assessees or relates to accommodation entries.

Sound Casting (P) Ltd. v. Dy. CIT
250 CTR 119 · 2012 · High Court
51
citing judgments

An assessment cannot be reopened beyond four years from the end of the relevant assessment year unless the assessee failed to make a full and true disclosure of all material facts necessary for assessment.

ACIT v. CEAT Ltd.
449 ITR 171 · 2022 · Supreme Court
44
citing judgments

Reopening of an assessment beyond four years from the end of the relevant assessment year is invalid if it is based on a mere change of opinion or borrowed satisfaction, or if the reasons recorded do not explicitly allege the assessee's failure to truly and fully disclose all material facts necessary for assessment.

CIT v. Foramer Finance
251 ITR 416 · 2001 · High Court
41
citing judgments

Reopening assessments is permissible after four years if there was an escapement of income due to the assessee's failure to disclose material facts necessary for assessment, even if the initial assessment involved a change of opinion.

Dalmia P. Ltd. v. CIT
348 ITR 469 · 2012 · High Court
41
citing judgments

Reassessment proceedings are valid when there is a failure to disclose fully and truly all material facts necessary for assessment.

R 603 Mad. (14) Well Intertrade P. Ltd vs. CIT, 308 ITR 22 (Del) (15) Sitara Diamond P. Ltd. v. DCIT
343 ITR 183 · 2012 · High Court
40
citing judgments

Reopening assessment beyond four years under Section 147 is permissible only if the assessee failed to disclose fully and truly the material facts necessary for assessment. Mere change of opinion is not a valid ground for reopening.

Judgments citing material facts necessary for assessment

Sarena Private Limited, Delhi vs. Pr, CIT Centre Delhi-3, Delhi

ITA 2479/DEL/2024[2013-14]Status: DisposedITAT Delhi22 Aug 2025AY 2013-14

Bench: Shri Anubhav Sharma & Shri Manish Agarwal

For Appellant: Shri Ambareesha Agrawal, CA &For Respondent: Shri Mahesh Kumar, CIT-DR
Section 142(1)Section 143(1)Section 143(3)Section 147Section 263Section 263(1)

IN THE INCOME TAX APPELLATE TRIBUNAL DELHI BENCHES: G : NEW DELHI BEFORE SHRI ANUBHAV SHARMA, JUDICIAL MEMBER AND SHRI MANISH

Bhikhalal Prahaladrai Agarwal HUF, Gandhidham vs. Assistant Commissioner of Income Tax, Gandhidham Circle, Gandhidham

ITA 780/RJT/2024[2016-17]Status: DisposedITAT Rajkot21 Aug 2025AY 2016-17

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos.779&780/Rjt/2024 ("नधा"रण वष" / Assessment Years: 2011-12 & 2016-17) Bhikhalal Prahaladrai Agarwal- Vs. Assistant Commissioner Of Income Tax, Huf, Gandhidham Circle C/O. Sarda & Sarda, Sakar, 1St It Office, Plot No. 32, Sector No. 3, Near Floor, Dr. Radha-Krishnan Road, Iffco Colony, Gandhidham Opp. Rajkumar College Rajkot Gandhidham - 370201 Rajkot - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabha4638R (Assessee) (Respondent) Assessee By : Shri Vimal Desai, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 05/06/2025 Date Of Pronouncement : 21/08/2025

For Appellant: Shri Vimal Desai, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 10(38)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 68

assessee, there is no whisper, what to speak of any allegation, that the assessee had failed to disclose fully and truly all material facts necessary for assessment and that because of this failure there has been an escapement of income chargeable to tax. We also find that

Bhikhalal Prahladrai Agarwal HUF, Gandhidham vs. Assistant Commissioner of Income Tax Gandhidham Circle, Gandhidham

ITA 779/RJT/2024[2011-12]Status: DisposedITAT Rajkot21 Aug 2025AY 2011-12

Bench: Dr. Arjun Lal Saini & Shri Dinesh Mohan Sinhaआयकर अपील सं./Ita Nos.779&780/Rjt/2024 ("नधा"रण वष" / Assessment Years: 2011-12 & 2016-17) Bhikhalal Prahaladrai Agarwal- Vs. Assistant Commissioner Of Income Tax, Huf, Gandhidham Circle C/O. Sarda & Sarda, Sakar, 1St It Office, Plot No. 32, Sector No. 3, Near Floor, Dr. Radha-Krishnan Road, Iffco Colony, Gandhidham Opp. Rajkumar College Rajkot Gandhidham - 370201 Rajkot - 360001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aabha4638R (Assessee) (Respondent) Assessee By : Shri Vimal Desai, Ld. Ar Respondent By : Shri Abhimanyu Singh Yadav, Ld. Sr. Dr Date Of Hearing : 05/06/2025 Date Of Pronouncement : 21/08/2025

For Appellant: Shri Vimal Desai, Ld. ARFor Respondent: Shri Abhimanyu Singh Yadav, Ld. Sr. DR
Section 10(38)Section 142(1)Section 143(2)Section 143(3)Section 147Section 148Section 68

assessee, there is no whisper, what to speak of any allegation, that the assessee had failed to disclose fully and truly all material facts necessary for assessment and that because of this failure there has been an escapement of income chargeable to tax. We also find that

M/S. Aman Enterprises, Ranchi vs. DCIT Circle-1, Ranchi

In the result, this appeal of the assessee is allowed

ITA 134/RAN/2024[2011-12]Status: DisposedITAT Ranchi18 Aug 2025AY 2011-12

Bench: Shri George Mathan & Shri Ratnesh Nandan Sahaym/S Aman Enterprises, D.C.I.T., 22, Park Street, Near Doranda College, Circle-1, Vs. Ranchi-834002 (Jharkhand) Ranchi. Pan No. Aaifa 9921 A Appellant/ Assessee Respondent/ Revenue

Section 143Section 143(3)Section 144Section 147Section 148

that the revenue had failed to prove that there was a failure on the part of the assessee to disclose any material facts necessary for assessment. Hence, they had rightly come to the conclusion that when the assessment was made under section 143(3), no action could be taken under ... relevant assessment year unless there was a failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment. In the instant case, the relevant assessment year was 1997-98 and the Assessing Officer had issued notice for reopening under section

Assistant Commissioner of Income Tax (Central Circle), Bareilly vs. Varunarjun Trust, Lucknow

In the result, both the appeals are dismissed

ITA 620/LKW/2024[2016-17]Status: DisposedITAT Lucknow07 Aug 2025AY 2016-17

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 12ASection 133(6)Section 142(1)Section 148Section 153C

exercised where there was a failure on the part of the assessee to make the true return disclosing fully and truly all material facts necessary for assessment and were such reopening would be permissible after enquiry of 4 years, as provided under Proviso to Section ... satisfied that the income of the assessee has escaped assessment inter-alia for the reason of non disclosure of true and full material facts necessary for assessment. Thus the authority competent to initiate re-assessment proceedings must record his satisfaction that the income of the assessee had escaped assessment

Assistant Commissioner of Income Tax, Central Circle, Bareilly vs. Varunarjun Trust, Lucknow

In the result, both the appeals are dismissed

ITA 619/LKW/2024[2015-16]Status: DisposedITAT Lucknow07 Aug 2025AY 2015-16

Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria

Section 12ASection 133(6)Section 142(1)Section 148Section 153C

exercised where there was a failure on the part of the assessee to make the true return disclosing fully and truly all material facts necessary for assessment and were such reopening would be permissible after enquiry of 4 years, as provided under Proviso to Section ... satisfied that the income of the assessee has escaped assessment inter-alia for the reason of non disclosure of true and full material facts necessary for assessment. Thus the authority competent to initiate re-assessment proceedings must record his satisfaction that the income of the assessee had escaped assessment

Income Tax Officer, Coimbatore vs. Damayanti Ramachandran, Gn Mills Post, Coimbatore

ITA 149/CHNY/2025[2016-17]Status: DisposedITAT Chennai07 Aug 2025AY 2016-17

Bench: Hon'Ble Shri Manu Kumar Giri & Hon'Ble Shri S. R. Raghunathaआयकर अपील सं./Ita No.103/Chny/2025, निर्धारण वर्ष/Assessment Year: 2015-16 Income Tax Officer, Non-Corporate Ward-4(3) Coimbatore Damayanti Ramachandran, Pb No.5303, Gn Mills Post, Coimbatore, Tamil Nadu-641029 [Pan: Aabhd8298Q] (अपीलार्थी/Appellant) V. (प्रत्यर्थी/Respondent) Co No.19/Chny/2025, निर्धारण वर्ष/Assessment Year: 2015-16 Damayanti Ramachandran, Pb No.5303, Gn Mills Post, Coimbatore, Tamil Nadu-641029 [Pan: Aabhd8298Q] Income Tax Officer, Non-Corporate Ward-4(3) Coimbatore V. (अपीलार्थी/Appellant) (प्रत्यर्थी/Respondent) आयकर अपील सं./Ita No.149/Chny/2025, निर्धारण वर्ष/Assessment Year: 2016-17 Income Tax Officer, Non-Corporate Ward-4(3) Coimbatore Damayanti Ramachandran, Pb No.5303, Gn Mills Post, Coimbatore, Tamil Nadu-641029 [Pan: Aabhd8298Q] (अपीलार्थी/Appellant) V. (प्रत्यर्थी/Respondent) Co No.20/Chny/2025, निर्धारण वर्ष/Assessment Year: 2016-17 Damayanti Ramachandran, Pb No.5303, Gn Mills Post, Coimbatore, Tamil Nadu-641029 [Pan: Aabhd8298Q] Income Tax Officer, Non-Corporate Ward-4(3) Coimbatore (अपीलार्थी/Appellant) V. (प्रत्यर्थी/Respondent) अपीलार्थी की ओर से/ Appellant By Mr.Ketan K. Ved, C.A

Section 45(4)

आयकर अपीलीय अधिकरण, "सी" न्यायपीठ, चेन्नई। IN THE INCOME TAX APPELLATE TRIBUNAL 'C' BENCH: CHENNAI माननीय श्री मनु कुमार गिरि

Income Tax Officer, Coimbatore vs. Damayanti Ramachandran, Gn Mills Post, Coimbatore

In the result, both the appeals of revenue for the A

ITA 103/CHNY/2025[2015-16]Status: DisposedITAT Chennai07 Aug 2025AY 2015-16

Bench: Hon’Ble Shri Manu Kumar Giri & Hon’Ble Shri S. R. Raghunathaआयकर अपील सं./Ita No.103/Chny/2025, ननिाारण वर्ा/Assessment Year: 2015-16

For Appellant: Mr.Ketan K. Ved, C.AFor Respondent: Mr.Bipin C.N, CIT
Section 45(4)

आयकर अपीलीय अधिकरण, ‘’सी’’ न्यायपीठ, चेन्नई। IN THE INCOME TAX APPELLATE TRIBUNAL ‘C’ BENCH: CHENNAI माननीय श्री मनु कुमार गिरि

Mukesh Jain HUF, Jaipur vs. DCIT, Jaipur

In the result, the appeal of the assessee is allowed

ITA 620/JPR/2025[2010-11]Status: DisposedITAT Jaipur06 Aug 2025AY 2010-11

Bench: Reopening The Assessment & Without Independent Application Of Mind. Thus, The Action Of The Ld. Ao In Reopening The Assessment U/S 148 & The Consequent Reassessment Order So Passed Deserves To Be Held Bad In Law.

For Appellant: Sh. Tarun Mittal, CAFor Respondent: MS. Alka Gautam, CIT-DR
Section 143(3)Section 147Section 148Section 68

verified and moreover, in reasons supplied to assessee there was no allegation that it had failed to disclose fully and truly all material facts necessary for assessment and because of its failure there had been an escapement of income chargeable to tax, reopening of assessment after expiry of four years ... recorded, there is no allegation that there was any failure on the part of the assessee in not disclosing truly and fully material facts necessary for assessment. Under the circumstances, the assumption of the jurisdiction to reopen the assessment beyond the period of four years in exercise of powers under

Deputy Commissioner of Income Tax-1(1), Raipur vs. Usha Devi Singhania, Raipur

In the result, appeal of the revenue in ITA No

ITA 270/RPR/2025[2015-16]Status: DisposedITAT Raipur31 Jul 2025AY 2015-16

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.269 & 270/Rpr/2025 "नधा"रण वष" / Assessment Years : 2013-14 & 2015-16 The Deputy Commissioner Of Income Tax-1(1), Raipur (C.G.)

For Appellant: Shri Praveen Jain, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 139Section 142Section 143Section 147Section 148

even as per the aforesaid reasons recorded regarding any failure on the part of the assessee in disclosing fully and truly all material facts necessary for assessment during the relevant assessment year. That undisputedly reopening has been done beyond the period of four years, then the revenue mandatorily ... Officer has to record his conclusion that there was failure on the part of assessee in not disclosing fully and truly all material facts necessary for assessment of that particular assessment year, which is not appearing from the reading of the Annexure i.e. reasons for issuance of notice. 7. Considering

Deputy Commissioner of Income Tax-1(1), Raipur vs. Usha Devi Singhania, Raipur

In the result, appeal of the revenue in ITA No

ITA 269/RPR/2025[2013-14]Status: DisposedITAT Raipur31 Jul 2025AY 2013-14

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita Nos.269 & 270/Rpr/2025 "नधा"रण वष" / Assessment Years : 2013-14 & 2015-16 The Deputy Commissioner Of Income Tax-1(1), Raipur (C.G.)

For Appellant: Shri Praveen Jain, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 139Section 142Section 143Section 147Section 148

even as per the aforesaid reasons recorded regarding any failure on the part of the assessee in disclosing fully and truly all material facts necessary for assessment during the relevant assessment year. That undisputedly reopening has been done beyond the period of four years, then the revenue mandatorily ... Officer has to record his conclusion that there was failure on the part of assessee in not disclosing fully and truly all material facts necessary for assessment of that particular assessment year, which is not appearing from the reading of the Annexure i.e. reasons for issuance of notice. 7. Considering

Sterling Infrastructure Private Limited, Delhi vs. ACIT, Central Circle-15, Delhi

ITA 3982/DEL/2024[2014-2015]Status: DisposedITAT Delhi30 Jul 2025AY 2014-2015

Bench: Shri Anubhav Sharma & Shri Manish Agarwalassessment Years: 2014-15 Sterling Infrastructure Private Vs Acit, Limited, Central Circle-15, 20A, Rajpur Road, Delhi. Civil Lines, Delhi – 110 054. Pan: Aakcs7108Q (Appellant) (Respondent) Assessee By : Shri Ranjan Chopra, Advocate & Shri Jaspal Singh Sethi, Advocate Revenue By : Shri Mahesh Kumar, Cit-Dr Date Of Hearing : 03.07.2025 Date Of Pronouncement : 30.07.2025 Order Per Anubhav Sharma, Jm:

For Appellant: Shri Ranjan Chopra, Advocate &For Respondent: Shri Mahesh Kumar, CIT-DR
Section 143(3)Section 147Section 148Section 194CSection 196

clearly based on mere change of opinion, which is not permissible in law. The appellant had fully and truly disclosed all the material facts necessary for assessment of income for the year under reference and the same were duly examined by the Assessing Officer. Thus, in the absence ... initiated unless the income has escaped assessment by reason of the failure of the assessee to disclose fully and truly all material facts necessary for assessment. Reliance was placed on the decision in CIT Vs Kelvinator of India Ltd. [2010] 320 ITR 561 (SC) 4. Though ld. DR vehemently defended

M/S. Ashok Leyland Ltd., Chennai vs. DCIT, Ncc-8(1), Ltu-II, Chennai

In the result, appeal filed by the assessee is allowed

ITA 601/CHNY/2025[2010-11]Status: DisposedITAT Chennai29 Jul 2025AY 2010-11

Bench: Shri Aby T. Varkey & Shri Jagadish

Section 143(2)Section 143(3)Section 147Section 148Section 32(1)(iia)

time of original assessment and therefore it was not a case that the assessee had failed to disclose truly and fully all material facts necessary for assessment for that year and in that view of the matter, the AO could not have validly reopened the assessment ... material facts necessary for that assessment year. According to the Ld. DR, it cannot be said that assessee has fully disclosed all material facts necessary for assessment. He therefore does not want us to interfere with the AO’s action of reopening of the assessment. 6. We have heard

Bhagwandas Jagdish Prasad, Bagbahara vs. Income Tax Officer, Mahasamund

In the result, appeal of the assessee is allowed

ITA 413/RPR/2025[2014-15]Status: HeardITAT Raipur28 Jul 2025AY 2014-15

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.412 & 413/Rpr/2025 "नधा"रण वष" /Assessment Years : 2013-14 & 2014-15 Bhagwandas Jagdish Prasad Petrol Pump, Main Road, Bagbahara-493 449 (C.G.) Pan: Aamfb0173H .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Mahasamund (C.G.) ……""यथ" / Respondent

For Appellant: Shri Ravi Agrawal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 147Section 148

beyond the period of four years without recording any failure on the part of the assessee in disclosing fully and truly all material facts necessary for assessment. In these peripheries of the facts, I refer to the decision of the Hon’ble Jurisdictional High Court in the case of Hariom ... Officer has to record his conclusion that there was failure on the part of assessee in not disclosing fully and truly all material facts necessary for assessment of that particular assessment year, which is not appearing from the reading of the Annexure i.e. reasons for issuance of notice. 7. Considering

Bhagwandas Jagdish Prasad, Bagbahara vs. Income Tax Officer, Mahasamund

In the result, appeal of the assessee is allowed

ITA 412/RPR/2025[2013-14]Status: HeardITAT Raipur28 Jul 2025AY 2013-14

Bench: Shri Partha Sarathi Chaudhuryआयकर अपील सं./Ita Nos.412 & 413/Rpr/2025 "नधा"रण वष" /Assessment Years : 2013-14 & 2014-15 Bhagwandas Jagdish Prasad Petrol Pump, Main Road, Bagbahara-493 449 (C.G.) Pan: Aamfb0173H .......अपीलाथ" / Appellant बनाम / V/S. The Income Tax Officer, Mahasamund (C.G.) ……""यथ" / Respondent

For Appellant: Shri Ravi Agrawal, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 147Section 148

beyond the period of four years without recording any failure on the part of the assessee in disclosing fully and truly all material facts necessary for assessment. In these peripheries of the facts, I refer to the decision of the Hon’ble Jurisdictional High Court in the case of Hariom ... Officer has to record his conclusion that there was failure on the part of assessee in not disclosing fully and truly all material facts necessary for assessment of that particular assessment year, which is not appearing from the reading of the Annexure i.e. reasons for issuance of notice. 7. Considering

Shri Amit Mangilal Jain, Mumbai vs. ACIT, - 33(1), Mumbai

In the result, both the above appeals are allowed

ITA 3332/MUM/2019[2010-11]Status: DisposedITAT Mumbai28 Jul 2025AY 2010-11

Bench: Shri Sandeep Gosain & Shri Prabhash Shankar

For Appellant: Shri Naresh Jain & Shri Mahaveer Jain, ARsFor Respondent: Shri Ram Krishn Kedia, (Sr. DR)
Section 131Section 143(3)Section 147Section 148Section 153C

Akshay Doshi u/s. 131. Confirming the initiation of reassessment proceedings, in absence of any failure on the part of appellant to disclose material facts necessary for assessment, is bad in law and consequently the reassessment order needs to be quashed. 2. Without prejudice to the above and without admitting

Gupta Ashok Kumar, Hyderabad vs. Income Tax Officer, Ward-1(2), Hyderabad

In the result, appeal of the assessee allowed

ITA 376/HYD/2024[2014-15]Status: DisposedITAT Hyderabad25 Jul 2025AY 2014-15

Bench: Shri Manjunatha G & Shri Ravish Sood

For Appellant: CA, P Murali Mohan RaoFor Respondent: Shri Gurpreet Singh, Sr. AR
Section 148Section 68

bogus unsecured loan has been brought in by the appellant and that it had failed to disclose fully and truly all material facts necessary for assessment. On the other hands assessee-appellant submitted that the reassessment is not sustainable in view of the very basic fact that there

ACIT, Circle-34, Kolkata vs. Vinod Kumar Lahoti, Kokata

In the result, the appeal of the revenue is dismissed

ITA 2460/KOL/2024[2013-14]Status: DisposedITAT Kolkata25 Jul 2025AY 2013-14

Bench: Shri Rajesh Kumar&Shri Pradip Kumar Choubey]

Section 143(1)Section 143(2)Section 143(3)Section 147Section 148Section 69C

disposed of and the notice has been issued beyond four years without any failure of the assessee to disclose fully and truly material facts necessary for assessment. The assessee has further submitted that his income was assessed at returned income by the assessment order dated 22.12.2015 under Section

Avanindra Nath Agrawal, Raipur vs. Deputy Commissioner of Income Tax, Circle 1(1), Raipur

In the result, appeal of the assessee is allowed

ITA 128/RPR/2025[2012-13]Status: HeardITAT Raipur22 Jul 2025AY 2012-13

Bench: Shri Partha Sarathi Chaudhury & Shri Arun Khodpiaआयकर अपील सं. / Ita No.128/Rpr/2025 "नधा"रण वष" / Assessment Year : 2013-14 Avanindra Nath Agrawal 1063, Akansha, Geeta Nagar, Opportunity. Anupam Nagar Garden, Raipur (C.G.)-492 001 Pan: Aehpa0353D

For Appellant: Shri Rajesh Kumar Chawda, CAFor Respondent: Dr. Priyanka Patel, Sr. DR
Section 139Section 143Section 147Section 148

failed to bring on record any evidence suggesting any failure on the part of the assessee for disclosing truly and fully all material facts necessary for assessment. In this regard, the Ld. Sr. DR was directed to furnish report from the A.O and the said report was placed ... able to place on record any evidence regarding any failure on the part of the assessee “to disclose truly and fully all material facts necessary for assessment.” At the same time, ground taken by the A.O justifying the reopening beyond the period of 6 years saying that whenever there

Income Tax Officer, Ward-1, Jalna vs. Ashish Omprakash Mantri, Jalna

In the result, all the appeals filed by the Revenue are dismissed

ITA 148/PUN/2024[2012]Status: DisposedITAT Pune17 Jul 2025

Bench: Shri R. K. Panda & Ms Astha Chandra

For Appellant: Shri Kishor B PhadkeFor Respondent: Shri Amol Khairnar, CIT-DR
Section 10(38)Section 132Section 143(2)Section 143(3)Section 147Section 148Section 151

likely that the Assessing Officer would have come to the conclusion that there was no failure to disclose truly and fully all material facts necessary for assessment. Thus, hit by the proviso to section 147 of the Act. However, the Assessing Officer has not applied his mind to the information ... balance sheet along with return of income where various information/material were disclosed. However, the requisite full and true disclosure of all material facts necessary for assessment has not been made as noted above. It is pertinent to mention here that even though the assessee has produced book of accounts, annual