https://www.taxtmi.com/caselaws?id=440418 HC quashed the reopening of assessment u/s 147 initiated beyond four years on the ground of alleged bogus share capital and premium received from paper companies. The Court held that the proviso to s.147 bars reopening after four years unless there is failure by the assessee to fully and truly disclose all material facts. The recorded reasons did not identify any specific material fact not disclosed. Based on the original assessment record and concurrent findings of CIT(A) and ITAT, HC found no such failure. There was also no material to show the assessee knew the entries were bogus. Notice u/s 148 was set aside. en-us Mon, 10 Jul 2023 00:00:00 +0530 Tue, 09 Dec 2025 10:14:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=440418 HC quashed the reopening of assessment u/s 147 initiated beyond four years on the ground of alleged bogus share capital and premium received from paper companies. The Court held that the proviso to s.147 bars reopening after four years unless there is failure by the assessee to fully and truly disclose all material facts. The recorded reasons did not identify any specific material fact not disclosed. Based on the original assessment record and concurrent findings of CIT(A) and ITAT, HC found no such failure. There was also no material to show the assessee knew the entries were bogus. Notice u/s 148 was set aside. Case-Laws Income Tax Mon, 10 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=440418