https://www.taxtmi.com/caselaws?id=13989 Reopening under s.147 beyond four years was challenged on the ground that there was no omission or failure to disclose fully and truly all material facts, and no valid "reason to believe" income had escaped assessment. The HC held that the assessee had disclosed all primary facts, including material forming part of submissions before the AO, and the Revenue's case itself showed at most an alleged AO error, which cannot satisfy the proviso to s.147. The recorded reasons reflected lack of independent application of mind and mere reliance on an internal audit objection, amounting to a colourable exercise of jurisdiction. The reassessment notices were quashed and set aside. en-us Fri, 22 Jun 2001 00:00:00 +0530 Mon, 22 Dec 2025 17:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=13989 Reopening under s.147 beyond four years was challenged on the ground that there was no omission or failure to disclose fully and truly all material facts, and no valid "reason to believe" income had escaped assessment. The HC held that the assessee had disclosed all primary facts, including material forming part of submissions before the AO, and the Revenue's case itself showed at most an alleged AO error, which cannot satisfy the proviso to s.147. The recorded reasons reflected lack of independent application of mind and mere reliance on an internal audit objection, amounting to a colourable exercise of jurisdiction. The reassessment notices were quashed and set aside. Case-Laws Income Tax Fri, 22 Jun 2001 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=13989