https://www.taxtmi.com/caselaws?id=261093 The Court upheld the Tribunal's decision, ruling that the reopening of assessment was invalid as it was initiated beyond the four-year period without any failure on the part of the assessee to disclose material facts. The Court emphasized that the Assessing Officer's failure to consider material facts cannot be attributed to the assessee. Precedents, including the Supreme Court's decision in Commissioner of Income-Tax v. Kelvinator of India Ltd., were referenced to support the conclusion that reassessment must be based on tangible material. The appeal by the Department was dismissed, and the reassessment proceedings were set aside with no order as to costs. en-us Mon, 08 Jun 2015 00:00:00 +0530 Wed, 04 May 2016 12:40:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=261093 The Court upheld the Tribunal's decision, ruling that the reopening of assessment was invalid as it was initiated beyond the four-year period without any failure on the part of the assessee to disclose material facts. The Court emphasized that the Assessing Officer's failure to consider material facts cannot be attributed to the assessee. Precedents, including the Supreme Court's decision in Commissioner of Income-Tax v. Kelvinator of India Ltd., were referenced to support the conclusion that reassessment must be based on tangible material. The appeal by the Department was dismissed, and the reassessment proceedings were set aside with no order as to costs. Case-Laws Income Tax Mon, 08 Jun 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=261093