https://www.taxtmi.com/caselaws?id=20644 A reassessment notice issued beyond four years from the end of the relevant assessment year required prior satisfaction of the Chief Commissioner or Commissioner under section 151, and the absence of that approval rendered the notice invalid. Reopening after the four-year period also depended on a failure by the assessee to fully and truly disclose all material facts necessary for assessment; a mere mistaken understanding of the legal effect of a notification, without suppression of primary facts, did not meet that threshold. Excess depreciation allowed on that basis was insufficient to justify reopening. The notice under section 148 was therefore held invalid. en-us Thu, 13 Feb 1992 00:00:00 +0530 Mon, 16 Nov 2009 12:53:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=20644 A reassessment notice issued beyond four years from the end of the relevant assessment year required prior satisfaction of the Chief Commissioner or Commissioner under section 151, and the absence of that approval rendered the notice invalid. Reopening after the four-year period also depended on a failure by the assessee to fully and truly disclose all material facts necessary for assessment; a mere mistaken understanding of the legal effect of a notification, without suppression of primary facts, did not meet that threshold. Excess depreciation allowed on that basis was insufficient to justify reopening. The notice under section 148 was therefore held invalid. Case-Laws Income Tax Thu, 13 Feb 1992 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=20644