https://www.taxtmi.com/caselaws?id=249270 The Tribunal ruled in favor of the assessee, setting aside the re-opening under section 147 due to the absence of failure to disclose material facts. The re-opening notice issued after four years from the relevant assessment year was deemed invalid as the reasons recorded did not establish any failure on the part of the assessee. Consequently, the discussion on the merits of the addition made by the Assessing Officer was not addressed, and the Tribunal allowed the assessee's appeal based on the invalidity of the re-opening under section 147. en-us Wed, 25 Jun 2014 00:00:00 +0530 Wed, 09 Jul 2014 12:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=249270 The Tribunal ruled in favor of the assessee, setting aside the re-opening under section 147 due to the absence of failure to disclose material facts. The re-opening notice issued after four years from the relevant assessment year was deemed invalid as the reasons recorded did not establish any failure on the part of the assessee. Consequently, the discussion on the merits of the addition made by the Assessing Officer was not addressed, and the Tribunal allowed the assessee's appeal based on the invalidity of the re-opening under section 147. Case-Laws Income Tax Wed, 25 Jun 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=249270