Reassessment beyond four years barred where unsecured loan details were disclosed during scrutiny and no failure to disclose was shown.

Reassessment notice issued beyond four years could not be sustained where the Assessing Officer had, during scrutiny assessment under Section 143(3), specifically called for details of the unsecured loan and the assessee had furnished them before the assessment order was passed. On those facts, there was no suppression or failure to disclose true and correct particulars. The quashing of the reassessment proceedings and the notice under Section 148 was upheld.

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Issues: Whether the reassessment proceedings and notice were liable to be quashed where, during scrutiny assessment under Section 143(3), the Assessing Officer had called for details of the unsecured loan, the assessee had furnished them, and the reassessment was initiated beyond four years.

Analysis: The details relating to the unsecured loan had been specifically called for during scrutiny assessment and were furnished by the assessee before the assessment order under Section 143(3) was passed. On those facts, there was no suppression or failure to disclose true and correct particulars by the assessee. Since the reassessment proceedings were initiated beyond the period of four years, the challenge to the reassessment notice under Section 148 could not be sustained.

Conclusion: The quashing of the reassessment proceedings and the notice under Section 148 was upheld, and no interference was called for.

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