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HC held that reassessment proceedings for AY 2002-03 and 2003-04 were invalid as they were initiated beyond the four-year limitation period. The revenue failed to establish that the assessee intentionally suppressed material information. The error in the commencement date was considered inadvertent, not deliberate. For AY 2004-05, the reassessment was within the four-year period, but no material justification was found to reopen the original assessment. The court emphasized that reassessment is not a review process and must be based on tangible evidence of non-disclosure. Consequently, the writ appeal was dismissed, protecting the assessee's original tax assessments.
HC held that reassessment proceedings for AY 2002-03 and 2003-04 were invalid as they were initiated beyond the four-year limitation period. The revenue failed to establish that the assessee intentionally suppressed material information. The error in the commencement date was considered inadvertent, not deliberate. For AY 2004-05, the reassessment was within the four-year period, but no material justification was found to reopen the original assessment. The court emphasized that reassessment is not a review process and must be based on tangible evidence of non-disclosure. Consequently, the writ appeal was dismissed, protecting the assessee's original tax assessments.
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