Reopening after 4 years in absence of failure of Assessee to disclose fully & truly all material facts necessary for assessment is invalid

ACIT Vs Shiv Vegpro Pvt. Ltd. (ITAT Jaipur)

Reopening after 4 years in absence of failure of Assessee to disclose fully & truly all material facts necessary for assessment is invalid

AO has even not mentioned as on what account or transactions the assessee has taken the accommodation entry from Shree Ram Trading Co. It appears that the AO has just narrated the contents as received by him from the Investigation Wing without having all the details and Investigation Report. The AO even in the assessment order ha

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