Reopening of assessment u/s 147 - while reopening no allegation...

Reopening of assessment u/s 147 - while reopening no allegation was made by the learned AO of failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment which is the primary condition to be fulfilled for reopening of assessment beyond 4 years from the end of the relevant assessment year as stipulated by the statutory provisions, the reopening cannot be said to be justified at all. - AT