https://www.taxtmi.com/caselaws?id=361541 HC held that reopening the assessment beyond four years was invalid. The AO had originally allowed the loss from purchase and sale of tea (PTD) without distinguishing loss from tea grown in the assessee's own plantations and without apportioning it under Rule 8 as done for income. The subsequent reassessment was based only on a different application of Rule 8, not on any new or previously undisclosed material facts. As there was no failure by the assessee to fully and truly disclose material facts, the statutory condition for reopening under s.147 after four years was not satisfied. The appeal was dismissed, and the matter was decided in favour of the assessee. en-us Wed, 23 May 2018 00:00:00 +0530 Sat, 22 Nov 2025 13:16:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=361541 HC held that reopening the assessment beyond four years was invalid. The AO had originally allowed the loss from purchase and sale of tea (PTD) without distinguishing loss from tea grown in the assessee's own plantations and without apportioning it under Rule 8 as done for income. The subsequent reassessment was based only on a different application of Rule 8, not on any new or previously undisclosed material facts. As there was no failure by the assessee to fully and truly disclose material facts, the statutory condition for reopening under s.147 after four years was not satisfied. The appeal was dismissed, and the matter was decided in favour of the assessee. Case-Laws Income Tax Wed, 23 May 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=361541