ITAT quashes reopening of assessment as AO not alleged that Assessee failed to disclose material facts during Original Assessment

MRF Limited Vs ACIT (ITAT Chennai)

Conclusion: Since there was no allegation by AO on failure on the part of assessee to disclose fully and truly all material facts necessary for assessment, therefore, reopening of assessment was not based on sound footing and hence the impugned assessment order framed u/s.143(3) r.w.s. 147 was illegal and liable to be quashed.

Held: AO reopened assessment under section 147, for the reasons recorded as per which income cha

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