https://www.taxtmi.com/caselaws?id=210424 HC dismissed the revenue's appeal, affirming the Tribunal's order quashing reassessment proceedings initiated beyond four years. It held that the jurisdictional preconditions under Section 147 were not satisfied, as there was no failure or omission by the assessee to make a full and true disclosure of all material and primary facts. The original assessment record contained all relevant data, and any error was attributable to the assessing officer's incorrect legal inferences, not to nondisclosure by the assessee. Consequently, no substantial question of law arose, and the reopening of assessment was held invalid. en-us Mon, 28 Nov 2011 00:00:00 +0530 Wed, 03 Dec 2025 11:44:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=210424 HC dismissed the revenue's appeal, affirming the Tribunal's order quashing reassessment proceedings initiated beyond four years. It held that the jurisdictional preconditions under Section 147 were not satisfied, as there was no failure or omission by the assessee to make a full and true disclosure of all material and primary facts. The original assessment record contained all relevant data, and any error was attributable to the assessing officer's incorrect legal inferences, not to nondisclosure by the assessee. Consequently, no substantial question of law arose, and the reopening of assessment was held invalid. Case-Laws Income Tax Mon, 28 Nov 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=210424