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The Petitioner had disclosed truly and fully all the material facts and it was open to the AO to take the same into account in the course of the assessment proceedings or, in any case, it was open to the AO to issue notice for reassessment within normal period of 4 years from the date of assessment.

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Sec. 80-IB & 147 of the Income-tax Act, 1961 – Reassessment – Appellant-assessee challenged the Notice issued under section 148 of the Act, 1961 and the order of disposing of the Petitioner's objections to the reopening of the assessment in pursuance of the said notice. High Court allowed the writ Petition by quashing and set aside the impugned notice and the impugned order by holding:–there is absolutely no reference to any alleged material facts which the Petitioner failed to disclose in the course of the assessment proceedings. Rather, the impugned notice refers to the list, as well as the letter issued by the Petitioner itself, which is sought to be made basis for reopening of the assessment. In this case, it is apparent that all the primary facts were disclosed by the Petitioner – ANAND DEVELOPERS [2020] 271 TAXMAN 044 (BOM)

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