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The HC upheld the reopening of assessment beyond the four-year limitation period, finding the appellant had claimed a deduction twice and failed to make full and true disclosure of material facts during original assessment proceedings. The AO correctly exercised jurisdiction under s. 147 after discovering the false claim. The court dismissed the writ appeal, noting that the appellant had already pursued alternate remedy by filing an appeal before the CIT(A) on the same issues after the writ petition's dismissal. The HC confirmed the appellant could address the merits of reopening before the CIT(A), rejecting the appellant's contention that no double claim existed.
The HC upheld the reopening of assessment beyond the four-year limitation period, finding the appellant had claimed a deduction twice and failed to make full and true disclosure of material facts during original assessment proceedings. The AO correctly exercised jurisdiction under s. 147 after discovering the false claim. The court dismissed the writ appeal, noting that the appellant had already pursued alternate remedy by filing an appeal before the CIT(A) on the same issues after the writ petition's dismissal. The HC confirmed the appellant could address the merits of reopening before the CIT(A), rejecting the appellant's contention that no double claim existed.
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