Reopening of assessment u/s 147 - Notice after four years -...

Reopening of assessment u/s 147 - Notice after four years - reopening based on audit objections - The Income Tax Officer must determine for himself what is the effect and consequence of the law mentioned in the audit note and whether in consequence of the law which has come to his notice he can reasonably believe that income had escaped assessment. The basis of his belief must be the law of which he has now become aware. - Further there is nothing under this head to indicate that there was failure on the part of petitioner to truly and fully disclose any fact - Notice and order quashed - however admitted liability of tax by the assessee directed to be paid - HC