In the result, both the appeals are dismissed
Bench: Shri Anadee Nath Misshra & Shri Subhash Malguria
217 (Allahabad). The Division Bench therein categorically held that as the revenue failed to make out a case that the assessee had failed to disclose fully and truly the material facts necessary for assessment, the reassessment proceedings started after the expiry of initial period are not maintainable and deserves to be set aside. Sri Gaurav Mahajan has tried to place