https://www.taxtmi.com/caselaws?id=456016 A reopening notice issued beyond four years was prima facie without jurisdiction because the assessee had already disclosed the relevant bank account in the original assessment and the balance sheet. As the assessment had been completed under Section 143(3) read with Section 153A, the first proviso to Section 147 required a failure to fully and truly disclose all material facts before reassessment could be validly initiated. The objections to reopening raised this disclosure point, but the order disposing of objections did not address it. Interim protection was granted restraining further action on the notice. en-us Thu, 07 Jun 2018 00:00:00 +0530 Fri, 21 Jun 2024 08:14:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=456016 A reopening notice issued beyond four years was prima facie without jurisdiction because the assessee had already disclosed the relevant bank account in the original assessment and the balance sheet. As the assessment had been completed under Section 143(3) read with Section 153A, the first proviso to Section 147 required a failure to fully and truly disclose all material facts before reassessment could be validly initiated. The objections to reopening raised this disclosure point, but the order disposing of objections did not address it. Interim protection was granted restraining further action on the notice. Case-Laws Income Tax Thu, 07 Jun 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=456016