Disclosure of different due date in filed return from that claimed in reassessment proceedings amount to non-disclosure of full facts

Brief of the case:

• The ITAT Delhi in the case of ITO vs. Shree Rajeev Goenka that assessee cannot be said to make full and correct disclosure of all the facts if the return of income due date which he mentioned in return filed is different from the due date he claimed during reassessment proceedings.
• Accordingly , the claim of the assessee during reassessment proceedings that due date of filling return of income was some other than date as declared in return filed would be a case of non-disclosure of all facts during the course of assessment u/s 14 3(3) and therefore, the restriction contained in 1^st provisio to sec 147 won’t apply.

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