https://www.taxtmi.com/caselaws?id=14636 The court upheld the validity of proceedings initiated under section 147 of the Income-tax Act, 1961, for reopening assessments based on material collected during an enquiry, not solely on the direction of a superior officer. The doctrine of merger did not apply as the reopening was supported by new evidence. The court clarified that proceedings were not solely influenced by a superior authority but based on the enquiry's findings. It was noted that the petitioner failed to fully disclose material facts initially, justifying the reassessment. The court held that the limitation for reopening assessments beyond four years applied in cases of non-disclosure of material facts, dismissing the writ applications. en-us Fri, 29 Sep 2000 00:00:00 +0530 Fri, 17 Jul 2009 16:37:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=14636 The court upheld the validity of proceedings initiated under section 147 of the Income-tax Act, 1961, for reopening assessments based on material collected during an enquiry, not solely on the direction of a superior officer. The doctrine of merger did not apply as the reopening was supported by new evidence. The court clarified that proceedings were not solely influenced by a superior authority but based on the enquiry's findings. It was noted that the petitioner failed to fully disclose material facts initially, justifying the reassessment. The court held that the limitation for reopening assessments beyond four years applied in cases of non-disclosure of material facts, dismissing the writ applications. Case-Laws Income Tax Fri, 29 Sep 2000 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=14636