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HC quashed notice for reopening assessment under s.147 due to AO's failure to specify which material facts were not fully disclosed by petitioner. Court emphasized that reasons for reopening must establish clear link between grounds and evidence, which cannot be supplemented later through affidavits or oral submissions. Since reopening was attempted beyond four-year limitation period, AO needed to demonstrate petitioner's failure to disclose material facts fully and truly. Following precedent, Court held that reopening restrictions must be evaluated solely based on recorded reasons, without subsequent additions or modifications. Notice invalidated as AO failed to meet statutory requirements for assessment reopening beyond limitation period.
HC quashed notice for reopening assessment under s.147 due to AO's failure to specify which material facts were not fully disclosed by petitioner. Court emphasized that reasons for reopening must establish clear link between grounds and evidence, which cannot be supplemented later through affidavits or oral submissions. Since reopening was attempted beyond four-year limitation period, AO needed to demonstrate petitioner's failure to disclose material facts fully and truly. Following precedent, Court held that reopening restrictions must be evaluated solely based on recorded reasons, without subsequent additions or modifications. Notice invalidated as AO failed to meet statutory requirements for assessment reopening beyond limitation period.
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