The ITAT allowed the assessee's appeal against the reopening of...

The ITAT allowed the assessee's appeal against the reopening of assessment u/s 147 beyond the four-year period. The Assessing Officer failed to record a finding that the escapement of income was attributable to the assessee's failure to fully and truly disclose material facts. The Tribunal held that since the assessee had disclosed all facts in the return filed u/s 139(1) and the case was scrutinized u/s 143(3), the reopening beyond four years without establishing the assessee's failure to disclose material facts rendered the reassessment proceedings nullity, relying on the Supreme Court's decision in CEAT Ltd.