https://www.taxtmi.com/caselaws?id=32730 Reassessment initiated beyond four years from the end of the assessment year was barred because the assessee had already disclosed all primary material facts relating to the depreciation claim and lease transactions. The Assessing Officer had called for invoices, lease details and other particulars, and had also issued notices to lessees and suppliers under section 133(6); the assessment was completed on that material. On those facts, there was no failure to disclose fully and truly all material facts, and any omission lay only in the original assessment reasoning. The proviso to section 147 therefore prevented reopening, and the reassessment was held invalid. en-us Wed, 31 Oct 2007 00:00:00 +0530 Wed, 25 Mar 2009 00:00:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=32730 Reassessment initiated beyond four years from the end of the assessment year was barred because the assessee had already disclosed all primary material facts relating to the depreciation claim and lease transactions. The Assessing Officer had called for invoices, lease details and other particulars, and had also issued notices to lessees and suppliers under section 133(6); the assessment was completed on that material. On those facts, there was no failure to disclose fully and truly all material facts, and any omission lay only in the original assessment reasoning. The proviso to section 147 therefore prevented reopening, and the reassessment was held invalid. Case-Laws Income Tax Wed, 31 Oct 2007 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=32730