https://www.taxtmi.com/caselaws?id=446376 The ITAT Delhi quashed the reopening of assessment under section 147 where notice was issued beyond four years from the assessment year end. The tribunal held that the AO failed to establish that the assessee had not made full and true disclosure of material facts, which is mandatory when reopening beyond four years under the proviso to section 147. The reasons recorded by the AO were inadequate and did not specify which facts were not disclosed by the assessee. Following the precedent in Hindustan Lever Ltd case, the tribunal emphasized that reasons must be self-explanatory and establish a vital link between conclusion and evidence. The reopening was quashed in favor of the assessee. en-us Thu, 05 Oct 2023 00:00:00 +0530 Fri, 01 Dec 2023 11:24:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446376 The ITAT Delhi quashed the reopening of assessment under section 147 where notice was issued beyond four years from the assessment year end. The tribunal held that the AO failed to establish that the assessee had not made full and true disclosure of material facts, which is mandatory when reopening beyond four years under the proviso to section 147. The reasons recorded by the AO were inadequate and did not specify which facts were not disclosed by the assessee. Following the precedent in Hindustan Lever Ltd case, the tribunal emphasized that reasons must be self-explanatory and establish a vital link between conclusion and evidence. The reopening was quashed in favor of the assessee. Case-Laws Income Tax Thu, 05 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446376