Reassessment limitation under Section 148 fails where reopening is issued after four years despite full disclosure.

A notice issued under Section 148 of the Income-tax Act was held time-barred because it was issued after four years despite the assessee's full and complete disclosure. The Tribunal found that the reopening was beyond the limitation period and that the record supported complete disclosure, so the reassessment could not proceed. The High Court found no basis to disturb that conclusion, and the reassessment proceedings were not sustained.

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Issues: Whether the notice issued under Section 148 of the Income-tax Act, 1961 was barred by limitation because it was issued beyond four years despite full and complete disclosure by the assessee.

Analysis: The Tribunal had found that the notice for reopening the assessment was issued after the expiry of four years and that the record showed full and complete disclosure by the assessee. On that basis, the reassessment proceedings were held to be time-barred. The High Court found no reason to interfere with that conclusion.

Conclusion: The notice under Section 148 was barred by limitation and the reassessment proceedings could not be sustained.

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