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Mere disclosure of receipt of unsecured loans would not be sufficient to avoid reassessment in case where the return was accepted without scrutiny. Further, the AO has only referred to the assessment of the subsequent assessment year to demonstrate the nature of unsecured loans received by the assessee. There is no provision which would require him to await finality of such assessment before issuing the notice of reassessment.

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Section 245D of the Income Tax Act, 1961 — Settlement of cases — Writ petition to quash the order of Settelement Commission was not maintainable as order of the Commissioner does not take notice of the paper book, if any, filed by the assessee. a copy thereof had not been provided to the Revenue as contended — Principal Commissioner of income tax vs. Union of India [2019] 310 CTR (Patna ) 29

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