Reasons Based on Material Already Available on Record Invalidates Reopening

DCIT Vs Paveljeet Singh Ruppal (ITAT Delhi)

The Assessing Officer has to demonstrate from the records that there has been a failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment. Here in this case, the assessee has duly disclosed the factum of total secured loan, total interest claimed, total advances given, etc. All these facts were duly available on the record at the time of original assessment proceedings. The ‘reasons recorded’ itself speaks that the point on which Assessing Officer has sough

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