https://www.taxtmi.com/caselaws?id=426992 The Court held that the reassessment proceedings under Section 147 of the Income Tax Act were invalid as the Department failed to establish any failure to disclose material facts by the petitioner. The Court emphasized that no action can be taken after four years from the end of the relevant assessment year unless there was a failure to disclose material facts. Since the initial assessment thoroughly examined the VGF grant and expenditure claim, and no new material post-assessment indicated incomplete disclosure, the limitation period applied, resulting in the reassessment being deemed invalid. The writ petition was allowed in favor of the petitioner. en-us Wed, 03 Aug 2022 00:00:00 +0530 Tue, 30 Aug 2022 10:10:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=426992 The Court held that the reassessment proceedings under Section 147 of the Income Tax Act were invalid as the Department failed to establish any failure to disclose material facts by the petitioner. The Court emphasized that no action can be taken after four years from the end of the relevant assessment year unless there was a failure to disclose material facts. Since the initial assessment thoroughly examined the VGF grant and expenditure claim, and no new material post-assessment indicated incomplete disclosure, the limitation period applied, resulting in the reassessment being deemed invalid. The writ petition was allowed in favor of the petitioner. Case-Laws Income Tax Wed, 03 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=426992