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The reopening of the Section 34 assessment, the issue of Assisi engaged in the manufacture and sale of welding electrodes, was opened on the basis that Assisi's income from drawing the wire for certain parties which he did not disclose was related to the issue. I kept the facts in mind. The evidence and the contents of the record in his order confirmed the investigating officer's finding that the Assisi had obtained income from wire drawing for others after allegations that they were reopening the case.

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