https://www.taxtmi.com/caselaws?id=755414 The ITAT Mumbai quashed the reopening of assessment initiated near the end of the sixth year from the relevant assessment year. The tribunal held that the AO failed to demonstrate any failure by the assessee to disclose material facts fully and truly. The assessee had properly disclosed sundry creditors, sales details, and loss on cancellation of sales during original assessment proceedings. The AO's presumption that six-year-old liability constituted deemed cessation was incorrect in law. Since there was full disclosure and no failure to provide material facts, the AO lacked jurisdiction to reopen beyond four years. The entire reassessment proceedings were quashed and the assessee's appeal was allowed. en-us Fri, 10 May 2024 00:00:00 +0530 Fri, 12 Jul 2024 08:36:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=755414 The ITAT Mumbai quashed the reopening of assessment initiated near the end of the sixth year from the relevant assessment year. The tribunal held that the AO failed to demonstrate any failure by the assessee to disclose material facts fully and truly. The assessee had properly disclosed sundry creditors, sales details, and loss on cancellation of sales during original assessment proceedings. The AO's presumption that six-year-old liability constituted deemed cessation was incorrect in law. Since there was full disclosure and no failure to provide material facts, the AO lacked jurisdiction to reopen beyond four years. The entire reassessment proceedings were quashed and the assessee's appeal was allowed. Case-Laws Income Tax Fri, 10 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=755414