Reopening of income tax assessment after scrutiny disclosure invalidated where no suppression and reassessment was time barred.

Reopening of income-tax assessment was invalid where the assessee disclosed unsecured loan details during scrutiny and the assessing officer completed assessment under the scrutiny provision thereafter. Because the information was furnished at the 143(3) stage, there was no suppression of facts to justify reopening, and reassessment action initiated beyond the four-year period was time barred. The challenge to the reassessment notice was upheld and the reassessment proceedings were quashed; the higher forum declined to interfere with that result on discretionary review.

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The Supreme Court of India dismissed the Special Leave petition, upholding the High Court's decision to quash re-assessment proceedings and notice under Section 148 of the Income Tax Act. The Assessing Officer had requested and received details regarding unsecured loans from the Assessee during Scrutiny Assessment under Section 143(3). No suppression of facts was found, and re-assessment proceedings were initiated beyond the four-year period. No interference by the Court was deemed necessary.

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