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The HC held that the reopening of assessment beyond four years was without jurisdiction as the reasons did not disclose any material facts that the assessee failed to disclose during the original assessment proceedings. Merely reproducing the proviso's wordings does not satisfy the jurisdictional condition for reopening. The reasons recorded were based on the assessee's case records filed during the assessment, which is impermissible for reopening after four years under the first proviso to Section 147. The HC ruled in favor of the assessee.
The HC held that the reopening of assessment beyond four years was without jurisdiction as the reasons did not disclose any material facts that the assessee failed to disclose during the original assessment proceedings. Merely reproducing the proviso's wordings does not satisfy the jurisdictional condition for reopening. The reasons recorded were based on the assessee's case records filed during the assessment, which is impermissible for reopening after four years under the first proviso to Section 147. The HC ruled in favor of the assessee.
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