Reopening assessments beyond four years requires nondisclosure of material facts; mere change of opinion or general allegations invalidates reassessme...
Reopening of assessment was quashed where the AO relied uncritically on AIR information without independent application of mind; the statutory test requires information with a direct nexus to form a belief that income escaped assessment, and treating transmission as conclusive or assuming return was not filed vitiated the formation of belief. The Addl. CIT's approval was held mechanical and based on incomplete facts, and the appellate tribunal upheld CIT(A)'s decision to quash the reopening, deciding against the revenue.
Reopening of assessment was quashed where the AO relied uncritically on AIR information without independent application of mind; the statutory test requires information with a direct nexus to form a belief that income escaped assessment, and treating transmission as conclusive or assuming return was not filed vitiated the formation of belief. The Addl. CIT's approval was held mechanical and based on incomplete facts, and the appellate tribunal upheld CIT(A)'s decision to quash the reopening, deciding against the revenue.
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