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In favour of revenue.If on the basis of subsequent valid information, the Assessing Officer forms a reason to believe on satisfying the twin conditions prescribed under section 147 of the Act that no full and true disclosure of facts was made by the assessee at the time of original assessment and, therefore, the income chargeable to tax had escaped assessment, his belief and the notice of reassessment based on such belief/opinion needs no interference.

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Section 48 & 147 of the Income-tax Act, 1961—Capital gain— The information furnished at the time of original assessment, when by subsequent information received from the Deputy Commissioner of Income-tax itself found to be controverted, the objection to the notice of reassessment under section 147 must fail- If on the basis of subsequent valid information, the Assessing Officer forms a reason to believe on satisfying the twin conditions prescribed under section 147 that no full and true disclosure of facts was made by the assessee at the time of original assessment and, therefore, the income chargeable to tax had escaped assessment, his belief and the notice of reassessment based on such belief/opinion needs no interference-—J.P. ISCON LTD. vs. Dy. CIT. [2018] 1 ITCD Online 353 (GUJ)

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