https://www.taxtmi.com/caselaws?id=13907 HC upheld the section 148 notice, finding reassessment permissible despite lapse of four years because income had escaped assessment. The court held that the AO had overlooked an item representing unpaid purchases, which led to suppression of income, and this was not merely a change of opinion. Under the proviso to section 147 and Explanation 1, mere production of books does not constitute full disclosure; since the AO had not considered the unpaid-purchase item in the original assessment, issuance of the notice was sustained. en-us Mon, 17 Sep 2001 00:00:00 +0530 Fri, 03 Oct 2025 09:55:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=13907 HC upheld the section 148 notice, finding reassessment permissible despite lapse of four years because income had escaped assessment. The court held that the AO had overlooked an item representing unpaid purchases, which led to suppression of income, and this was not merely a change of opinion. Under the proviso to section 147 and Explanation 1, mere production of books does not constitute full disclosure; since the AO had not considered the unpaid-purchase item in the original assessment, issuance of the notice was sustained. Case-Laws Income Tax Mon, 17 Sep 2001 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=13907