Central Electronics Ltd., New Delhi vs Department Of Income Tax
5. Ld. DR strongly relied on the order of Assessing Officer and the
decisions of Hon'ble Supreme Court in the case of Phool Chand Bajrang Lal
vs ITO (1993) 203 ITR 456 (SC); Bawa Abhai Singh vs DCIT 253 ITR 83
(Del); Ram Prasad vs ITO (1995) 82 Taxman 199 (All.). On the contrary,
Ld. AR submitted that reopening of the assessment was bad in law and the
entire material was available during the original assessment. He submitted
that the reopening of assessment was made after 4 years and such reopening
was made without establishing the assessee's failure to disclose the material
facts.