https://www.taxtmi.com/caselaws?id=340673 Reassessment initiated beyond four years requires a failure by the assessee to fully and truly disclose all material facts. Commission payments had been specifically examined during the original assessment and the assessee had responded, leaving no fresh material demonstrating non-disclosure. Reopening on that basis was therefore invalid. CBDT Circular No. 7/2009 could not be applied retrospectively to commission payments made before its issue, so a disallowance founded on the circular could not stand. The reassessment was quashed, and the deletion of the addition remained undisturbed. en-us Thu, 16 Mar 2017 00:00:00 +0530 Fri, 24 Mar 2017 13:30:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=340673 Reassessment initiated beyond four years requires a failure by the assessee to fully and truly disclose all material facts. Commission payments had been specifically examined during the original assessment and the assessee had responded, leaving no fresh material demonstrating non-disclosure. Reopening on that basis was therefore invalid. CBDT Circular No. 7/2009 could not be applied retrospectively to commission payments made before its issue, so a disallowance founded on the circular could not stand. The reassessment was quashed, and the deletion of the addition remained undisturbed. Case-Laws Income Tax Thu, 16 Mar 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=340673