https://www.taxtmi.com/caselaws?id=394226 The SC held that the assessing officer had sufficient material to form a prima facie view that income had escaped assessment, making the reopening notice valid. However, the court found that the assessee had disclosed all primary facts necessary for assessment and was not required to provide further assistance to the assessing officer. The revenue could not claim benefit of the extended 6-year limitation period due to full disclosure by the assessee. Regarding the 16-year limitation under the second proviso to Section 147, the court ruled that the revenue failed to properly invoke this provision in the original notice or supporting reasons, and could not introduce it later during rejection proceedings. Consequently, while the notice showed sufficient reasons to believe income had escaped assessment, the revenue's failure to establish non-disclosure of facts rendered the notice, issued after 4 years, liable to be quashed. en-us Fri, 03 Apr 2020 00:00:00 +0530 Thu, 17 Jul 2025 17:51:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=394226 The SC held that the assessing officer had sufficient material to form a prima facie view that income had escaped assessment, making the reopening notice valid. However, the court found that the assessee had disclosed all primary facts necessary for assessment and was not required to provide further assistance to the assessing officer. The revenue could not claim benefit of the extended 6-year limitation period due to full disclosure by the assessee. Regarding the 16-year limitation under the second proviso to Section 147, the court ruled that the revenue failed to properly invoke this provision in the original notice or supporting reasons, and could not introduce it later during rejection proceedings. Consequently, while the notice showed sufficient reasons to believe income had escaped assessment, the revenue's failure to establish non-disclosure of facts rendered the notice, issued after 4 years, liable to be quashed. Case-Laws Income Tax Fri, 03 Apr 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=394226