https://www.taxtmi.com/caselaws?id=208263 The Tribunal held that the reopening of the assessment under section 147, beyond the four-year limit, was not justified as the assessee had fully disclosed all material facts necessary for the assessment during the original proceedings. The Tribunal emphasized that the duty of the assessee is to disclose primary facts, not the inferences to be drawn from those facts. Consequently, the appeal of the assessee was allowed, and the reassessment was deemed unwarranted. en-us Thu, 30 Dec 2010 00:00:00 +0530 Fri, 24 Aug 2012 15:44:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=208263 The Tribunal held that the reopening of the assessment under section 147, beyond the four-year limit, was not justified as the assessee had fully disclosed all material facts necessary for the assessment during the original proceedings. The Tribunal emphasized that the duty of the assessee is to disclose primary facts, not the inferences to be drawn from those facts. Consequently, the appeal of the assessee was allowed, and the reassessment was deemed unwarranted. Case-Laws Income Tax Thu, 30 Dec 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=208263