https://www.taxtmi.com/caselaws?id=756251 ITAT Chennai quashed reopening notice issued under Section 148 beyond four-year limitation period. Original assessment was completed under Section 143(3) on 30.03.2015 for AY 2012-13, but reopening notice was issued on 25.03.2019. AO failed to establish assessee's failure to disclose material facts fully and truly. Following SC precedent in Foramer France, tribunal held that without such failure, proviso to Section 147 applies and notice was time-barred. Reopening was invalid due to limitation. en-us Thu, 30 May 2024 00:00:00 +0530 Tue, 30 Jul 2024 10:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=756251 ITAT Chennai quashed reopening notice issued under Section 148 beyond four-year limitation period. Original assessment was completed under Section 143(3) on 30.03.2015 for AY 2012-13, but reopening notice was issued on 25.03.2019. AO failed to establish assessee's failure to disclose material facts fully and truly. Following SC precedent in Foramer France, tribunal held that without such failure, proviso to Section 147 applies and notice was time-barred. Reopening was invalid due to limitation. Case-Laws Income Tax Thu, 30 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=756251