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ITAT held that reopening assessment under Section 147 after four-year limitation period was invalid. Where assessment under Section 153A was already completed and four years had expired, action under Section 148 requires failure by assessee to disclose material facts fully and truly. Since Assessing Officer failed to record reasons establishing such non-disclosure in the reasons recorded, the reopening proceedings were vitiated. The tribunal quashed the entire reopening proceedings as the mandatory condition under first proviso to Section 148 was not satisfied, rendering the notice issued beyond limitation period legally unsustainable.
ITAT held that reopening assessment under Section 147 after four-year limitation period was invalid. Where assessment under Section 153A was already completed and four years had expired, action under Section 148 requires failure by assessee to disclose material facts fully and truly. Since Assessing Officer failed to record reasons establishing such non-disclosure in the reasons recorded, the reopening proceedings were vitiated. The tribunal quashed the entire reopening proceedings as the mandatory condition under first proviso to Section 148 was not satisfied, rendering the notice issued beyond limitation period legally unsustainable.
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