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Reopening of assessment u/s 147 - The High Court noted that the extended period of six years for reassessment could only be invoked under specific circumstances, one of which is the failure to disclose all material facts. - The Court observed that while the Assessing Officer had invoked the extended period of limitation for reassessment, there was no finding in the reasons furnished for reassessment that the petitioner had failed to disclose fully and truly all material facts necessary for assessment. Without such a finding, the Court held that the entire proceeding would be void and a nullity.
Reopening of assessment u/s 147 - The High Court noted that the extended period of six years for reassessment could only be invoked under specific circumstances, one of which is the failure to disclose all material facts. - The Court observed that while the Assessing Officer had invoked the extended period of limitation for reassessment, there was no finding in the reasons furnished for reassessment that the petitioner had failed to disclose fully and truly all material facts necessary for assessment. Without such a finding, the Court held that the entire proceeding would be void and a nullity.
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