https://www.taxtmi.com/caselaws?id=207822 HC held that reopening assessment under section 147 by issuing notice under section 148 after four years was invalid where the assessee had not failed to disclose fully and truly all material facts. Although AO disputed the 80-IB(10) deduction as illegitimate, the court found mere assertion of developer status in returns did not constitute concealment or omission of material facts. In absence of such failure, assumption of jurisdiction after four years was illegal, and the challenge succeeded in favor of the assessee. en-us Wed, 02 Feb 2011 00:00:00 +0530 Mon, 25 Aug 2025 12:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=207822 HC held that reopening assessment under section 147 by issuing notice under section 148 after four years was invalid where the assessee had not failed to disclose fully and truly all material facts. Although AO disputed the 80-IB(10) deduction as illegitimate, the court found mere assertion of developer status in returns did not constitute concealment or omission of material facts. In absence of such failure, assumption of jurisdiction after four years was illegal, and the challenge succeeded in favor of the assessee. Case-Laws Income Tax Wed, 02 Feb 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=207822