In the result, all the captioned appeals of the assessee stand allowed
Bench: Sri Sanjay Garg & Shri Sanjay Awasthi
section 147 of the Act, as applicable for the assessment year under consideration as there is no allegation of any failure on the part of the assessee to fully and truly disclose all the material facts necessary for assessment for the assessment year under consideration. Admittedly, as noted above, the earlier assessment in this case was carried out u/s. 153A/143