https://www.taxtmi.com/caselaws?id=761242 ITAT Raipur allowed the assessee's appeal against reopening proceedings under sections 147/148 initiated after four years. The tribunal held that since the original assessment under section 143(3) was completed with proper scrutiny of books and accounts, and no failure to disclose material facts was established by the revenue, the reopening beyond four years was invalid. The AO lacked jurisdiction as the case fell within the first proviso to section 147, making the subsequent assessment order unsustainable and liable to be annulled. en-us Mon, 21 Oct 2024 00:00:00 +0530 Thu, 07 Nov 2024 08:47:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=761242 ITAT Raipur allowed the assessee's appeal against reopening proceedings under sections 147/148 initiated after four years. The tribunal held that since the original assessment under section 143(3) was completed with proper scrutiny of books and accounts, and no failure to disclose material facts was established by the revenue, the reopening beyond four years was invalid. The AO lacked jurisdiction as the case fell within the first proviso to section 147, making the subsequent assessment order unsustainable and liable to be annulled. Case-Laws Income Tax Mon, 21 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=761242