https://www.taxtmi.com/caselaws?id=273631 Reopening after four years was invalid because the Assessing Officer did not identify any specific failure by the assessee to fully and truly disclose material facts, as required by the proviso to Section 147 where the original assessment was completed under Section 143(3). General reliance on Investigation Wing information was insufficient, so the reassessment was quashed. On the merits, the assessee had produced incorporation details, PAN, confirmation, board resolution, return acknowledgement and cheque payment proof for the share applicant, while the revenue relied mainly on unverified material and an unserved summons. The addition for share application money and commission was therefore not sustainable and was deleted. en-us Thu, 18 Mar 2010 00:00:00 +0530 Thu, 05 Jul 2018 12:38:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=273631 Reopening after four years was invalid because the Assessing Officer did not identify any specific failure by the assessee to fully and truly disclose material facts, as required by the proviso to Section 147 where the original assessment was completed under Section 143(3). General reliance on Investigation Wing information was insufficient, so the reassessment was quashed. On the merits, the assessee had produced incorporation details, PAN, confirmation, board resolution, return acknowledgement and cheque payment proof for the share applicant, while the revenue relied mainly on unverified material and an unserved summons. The addition for share application money and commission was therefore not sustainable and was deleted. Case-Laws Income Tax Thu, 18 Mar 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=273631