Reopening of assessment u/s 147 - Reopening based on audit...

Reopening of assessment u/s 147 - Reopening based on audit objections - reasons to believe - High Court observed that, reopening an assessment beyond four years requires not only a reason to believe that income has escaped assessment but also a failure on the part of the assessee to fully and truly disclose all material facts necessary for assessment. - Accordingly, High Court held that, the reasons for reopening were not in compliance with the proviso to Section 147 of the Act and, therefore, quashed the notice and order.