https://www.taxtmi.com/caselaws?id=202049 Validity of reopening an income-tax assessment beyond four years turned on whether the statutory condition precedent was satisfied; the assessee had made complete disclosure including an audit report and specific disclosure about capitalization of interest, and therefore there was no nondisclosure or escapement of income. The assessing officers reasons and the order on objections did not rely on the ground later urged by Revenue and failed to consider the assessees explanation; hence the reopening lacked the necessary foundation and could not be sustained. The audit report disclosures were held not to fall within the scope of the prohibition in Explanation 1 to reopening provisions. en-us Mon, 14 Jun 2010 00:00:00 +0530 Thu, 29 Jan 2026 18:12:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=202049 Validity of reopening an income-tax assessment beyond four years turned on whether the statutory condition precedent was satisfied; the assessee had made complete disclosure including an audit report and specific disclosure about capitalization of interest, and therefore there was no nondisclosure or escapement of income. The assessing officers reasons and the order on objections did not rely on the ground later urged by Revenue and failed to consider the assessees explanation; hence the reopening lacked the necessary foundation and could not be sustained. The audit report disclosures were held not to fall within the scope of the prohibition in Explanation 1 to reopening provisions. Case-Laws Income Tax Mon, 14 Jun 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=202049