In the result, the appeal of the assessee in ITANo
Bench: Smt.Annapurna Gupta & Shri Siddhartha Nautiyal
36(1)(viia) which was not done. It is evident from the above facts that the assessee had not truly and fully disclosed material facts necessary for its assessment for the year under consideration thereby necessitating reopening u/s.147 of the Act.” 11. He stated that what the AO has considered to be material fact was not material fact, but only