https://www.taxtmi.com/caselaws?id=234031 Reopening an assessment beyond four years is invalid unless the Revenue can show that the assessee failed to disclose fully and truly all material facts necessary for assessment. Here, the return disclosed the provision written back and the accompanying notes explained its nature, which was sufficient to alert the Assessing Officer and permit further enquiry if needed. The absence of enquiry in the original assessment, by itself, did not satisfy the statutory condition for reopening after four years. The High Court therefore quashed the reopening notice in favour of the assessee, noting that a similar notice in the assessee's own case had already been set aside on comparable facts. en-us Mon, 22 Apr 2013 00:00:00 +0530 Fri, 04 Apr 2014 17:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=234031 Reopening an assessment beyond four years is invalid unless the Revenue can show that the assessee failed to disclose fully and truly all material facts necessary for assessment. Here, the return disclosed the provision written back and the accompanying notes explained its nature, which was sufficient to alert the Assessing Officer and permit further enquiry if needed. The absence of enquiry in the original assessment, by itself, did not satisfy the statutory condition for reopening after four years. The High Court therefore quashed the reopening notice in favour of the assessee, noting that a similar notice in the assessee's own case had already been set aside on comparable facts. Case-Laws Income Tax Mon, 22 Apr 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=234031