https://www.taxtmi.com/caselaws?id=354947 Reopening beyond four years from the end of the assessment year requires a failure by the assessee to disclose fully and truly all material facts necessary for assessment. Here, the gratuity deduction claim, supporting accounts and related documents were disclosed in the original scrutiny assessment under section 143(3), and the reopening was based only on the view that the gratuity fund lacked the required approval for deduction. The court noted that, on these facts, the absence of an additional supporting document did not amount to nondisclosure of material facts. The reassessment notice was therefore not sustainable under the proviso to section 147 and was quashed. en-us Mon, 05 Feb 2018 00:00:00 +0530 Sat, 29 Jun 2019 16:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=354947 Reopening beyond four years from the end of the assessment year requires a failure by the assessee to disclose fully and truly all material facts necessary for assessment. Here, the gratuity deduction claim, supporting accounts and related documents were disclosed in the original scrutiny assessment under section 143(3), and the reopening was based only on the view that the gratuity fund lacked the required approval for deduction. The court noted that, on these facts, the absence of an additional supporting document did not amount to nondisclosure of material facts. The reassessment notice was therefore not sustainable under the proviso to section 147 and was quashed. Case-Laws Income Tax Mon, 05 Feb 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=354947