https://www.taxtmi.com/caselaws?id=212490 Reassessment beyond four years was discussed as invalid where the assessee had already disclosed the excise duty treatment in return materials, replies and tax audit records, leaving no identified failure to disclose fully and truly all material facts. For later years, reopening was discussed as sustainable because the original scrutiny had not examined the possible double deduction effect arising from the excise duty and stock valuation treatment, so it was not treated as a mere change of opinion. On the merits, excise duty on closing stock was treated as deductible where statutory duty was actually paid and no double deduction survived in the overall computation. Interest under section 234D was also discussed as not chargeable for the years before assessment year 2004-05. en-us Fri, 21 Oct 2011 00:00:00 +0530 Fri, 11 May 2012 16:26:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=212490 Reassessment beyond four years was discussed as invalid where the assessee had already disclosed the excise duty treatment in return materials, replies and tax audit records, leaving no identified failure to disclose fully and truly all material facts. For later years, reopening was discussed as sustainable because the original scrutiny had not examined the possible double deduction effect arising from the excise duty and stock valuation treatment, so it was not treated as a mere change of opinion. On the merits, excise duty on closing stock was treated as deductible where statutory duty was actually paid and no double deduction survived in the overall computation. Interest under section 234D was also discussed as not chargeable for the years before assessment year 2004-05. Case-Laws Income Tax Fri, 21 Oct 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=212490