https://www.taxtmi.com/caselaws?id=314188 The ITAT Mumbai held that reassessment proceedings initiated beyond four years were invalid. The AO issued notice based on information regarding alleged bogus unsecured loans but failed to establish that the assessee had not disclosed material facts fully and truly, as required under the First Proviso to section 147. The assessee had previously provided loan details, confirmations, and bank statements during earlier proceedings. The AO's reasons merely stated belief that income escaped assessment without alleging non-disclosure of material facts. Since the statutory pre-requisite for reopening beyond four years was not satisfied, the reassessment notice was held to be barred by limitation and without jurisdiction. The case was decided in favor of the assessee. en-us Fri, 18 Aug 2023 00:00:00 +0530 Thu, 23 May 2024 08:37:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=314188 The ITAT Mumbai held that reassessment proceedings initiated beyond four years were invalid. The AO issued notice based on information regarding alleged bogus unsecured loans but failed to establish that the assessee had not disclosed material facts fully and truly, as required under the First Proviso to section 147. The assessee had previously provided loan details, confirmations, and bank statements during earlier proceedings. The AO's reasons merely stated belief that income escaped assessment without alleging non-disclosure of material facts. Since the statutory pre-requisite for reopening beyond four years was not satisfied, the reassessment notice was held to be barred by limitation and without jurisdiction. The case was decided in favor of the assessee. Case-Laws Income Tax Fri, 18 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=314188