Jindal Power Limiteed, Raigarh vs Deputy Commissioner Of Incoe Tax , ... on 23 September, 2022
16.2 As the assessee had duly came forth with a full and true
disclosure of all material facts as regards the "primary facts" qua the
aforesaid issue, and was neither required to disclose the "secondary
facts" nor required to give any assistance to the A.O by disclosure of
the other facts, and it was for the A.O to decide what inferences were
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Jindal Power Limited Vs. DCIT-1(1)
ITA No. 199/RPR/2017
to be drawn from the facts before him, therefore, the reopening of the
assessee's case for the aforesaid reason would not be saved by the
extended time period contemplated in the "1st proviso" to Sec. 147 of
the Act.