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The ld AO has raised the ground of appeal that on the facts and in the circumstances of thecaseand in law, Ld. CIT (A) has erred in making a finding that the issue of CSR expenses (Corporate Social Responsibility) of Rs. 7,04,01,602/- was examined during the initial assessment proceedings. As the issue was not examined by the AO in the initial assessment proceedings, the findings of CIT(A) regarding change of opinion is wrong and factually incorrect.

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Sec. 147 of Income Tax Act, 1961—Reassessment— When there is no failure on the part of the assessee to disclose fully and truly all the material facts for assessment, it cannot come under the category of escapement of income and Assessing Officer has a duty to record reasons for reopening under s 148 prior to issuance of notice and mere recording of 'reason to believe' without mentioning that there was failure to disclose fully and truly all material facts, is not sufficient to reopen an assessment beyond four years and the reasons must record the material fact suppressed by the assessee, and the manner in which such material was suppressed and in the reasons recorded, there is an allegation that reason to believe is by reason of failure on the part of the assessee to disclose truly and fully all-material facts necessary for this order. - DEPUTY CIT V/s GAIL (INDIA) LTD. - [2020] 27 ITCD Online 055 (ITAT-DELHI)

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