Assessee cannot be blamed for non-disclosure if AO had such info during assessment proceeding

Rajbhushan Omprakash Dixit Vs DCIT (Bombay High Court) Undisputed fact is that all these documents were before the Assessing Officer when the original scrutiny under assessment under Section 153A read with 143(3) was made. It was in this background that the Assessee had, in his objections, asserted that the documents relied upon in the reasons were very much available with the Assessing Officer earlier. In this context, once the Department i.e. the Assessing Officer had certain information, material, or document before him during the assessment proceeding, irrespective of the source of such in...