https://www.taxtmi.com/caselaws?id=11166 Where reassessment is initiated beyond four years, the proviso to s. 147 mandates that the AO must have reason to believe that income escaped assessment due to the assessee's failure to disclose fully and truly all material facts; Explanation 2(c) cannot be applied in isolation to bypass this requirement. Since the assessee had furnished its annual report showing the VRS expenditure and its amortisation over 60 months, and the AO had allowed the deduction on that disclosed basis, there was no such failure of disclosure. The reopening was therefore held impermissible and set aside. en-us Wed, 26 Feb 2003 00:00:00 +0530 Fri, 26 Dec 2025 19:07:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=11166 Where reassessment is initiated beyond four years, the proviso to s. 147 mandates that the AO must have reason to believe that income escaped assessment due to the assessee's failure to disclose fully and truly all material facts; Explanation 2(c) cannot be applied in isolation to bypass this requirement. Since the assessee had furnished its annual report showing the VRS expenditure and its amortisation over 60 months, and the AO had allowed the deduction on that disclosed basis, there was no such failure of disclosure. The reopening was therefore held impermissible and set aside. Case-Laws Income Tax Wed, 26 Feb 2003 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=11166