https://www.taxtmi.com/caselaws?id=233829 The HC held that reassessment proceedings under section 148 were invalid as the AO failed to establish that the assessee had failed to disclose material facts fully and truly in the original return. The AO's reasons did not allege non-disclosure, and the initial assessment had already examined the identity, genuineness, and creditworthiness of the share applicants. Without such failure, reopening after four years is impermissible. The mere seizure of goods by DRI and penalty imposition did not justify reassessment absent a recorded belief of escaped income due to non-disclosure. The AO's action was held without jurisdiction, and the reassessment was quashed. en-us Tue, 07 May 2013 00:00:00 +0530 Mon, 11 Aug 2025 16:15:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=233829 The HC held that reassessment proceedings under section 148 were invalid as the AO failed to establish that the assessee had failed to disclose material facts fully and truly in the original return. The AO's reasons did not allege non-disclosure, and the initial assessment had already examined the identity, genuineness, and creditworthiness of the share applicants. Without such failure, reopening after four years is impermissible. The mere seizure of goods by DRI and penalty imposition did not justify reassessment absent a recorded belief of escaped income due to non-disclosure. The AO's action was held without jurisdiction, and the reassessment was quashed. Case-Laws Income Tax Tue, 07 May 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=233829