https://www.taxtmi.com/caselaws?id=752381 The ITAT Bangalore quashed a reassessment order issued under section 148 after four years from the relevant assessment year. The AO had reopened the assessment citing discrepancies regarding non-deduction of TDS on interest payments, non-inclusion of accrued interest on NSC, and non-compliance with Accounting Standard AS-7. The tribunal found that the AO failed to record any finding that the assessee had not disclosed material facts fully and truly. Since all relevant information was available during the original assessment under section 143(3), and the AO could not revisit the same records after four years without establishing failure to disclose material facts, the reopening was held invalid. The tribunal ruled in favor of the assessee. en-us Wed, 17 Jan 2024 00:00:00 +0530 Thu, 09 May 2024 07:21:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=752381 The ITAT Bangalore quashed a reassessment order issued under section 148 after four years from the relevant assessment year. The AO had reopened the assessment citing discrepancies regarding non-deduction of TDS on interest payments, non-inclusion of accrued interest on NSC, and non-compliance with Accounting Standard AS-7. The tribunal found that the AO failed to record any finding that the assessee had not disclosed material facts fully and truly. Since all relevant information was available during the original assessment under section 143(3), and the AO could not revisit the same records after four years without establishing failure to disclose material facts, the reopening was held invalid. The tribunal ruled in favor of the assessee. Case-Laws Income Tax Wed, 17 Jan 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=752381