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Reopening of assessment u/s 147 was invalid as there was no failure by the assessee to disclose material facts. The assessment was reopened solely based on information that some parties from whom the assessee made purchases were non-filers of GST. However, the purchases were already examined and accepted in the original assessment order u/s 143(3). The Appellate Tribunal held that there was no document or evidence revealing any income chargeable to tax that had escaped assessment. Since the time limit for reopening had expired and the first proviso to Section 147 was not satisfied, the reopening itself was bad in law and quashed. The assessment order was quashed, and the assessee's appeal was allowed.
Reopening of assessment u/s 147 was invalid as there was no failure by the assessee to disclose material facts. The assessment was reopened solely based on information that some parties from whom the assessee made purchases were non-filers of GST. However, the purchases were already examined and accepted in the original assessment order u/s 143(3). The Appellate Tribunal held that there was no document or evidence revealing any income chargeable to tax that had escaped assessment. Since the time limit for reopening had expired and the first proviso to Section 147 was not satisfied, the reopening itself was bad in law and quashed. The assessment order was quashed, and the assessee's appeal was allowed.
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