https://www.taxtmi.com/caselaws?id=761828 ITAT Mumbai allowed the assessee's appeal, quashing the second reopening notice u/s 148 issued beyond four years. The original assessment u/s 147 was completed on 27.11.2018, and the second notice was issued on 22.03.2019, exceeding the four-year limitation period which expired on 31.03.2017. The assessee had fully disclosed all material facts regarding share capital receipts in the original return and financial statements. The AO failed to establish any failure by the assessee to disclose facts truly and fully, making the reopening invalid under the proviso to section 147. en-us Fri, 25 Oct 2024 00:00:00 +0530 Sat, 16 Nov 2024 12:24:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=761828 ITAT Mumbai allowed the assessee's appeal, quashing the second reopening notice u/s 148 issued beyond four years. The original assessment u/s 147 was completed on 27.11.2018, and the second notice was issued on 22.03.2019, exceeding the four-year limitation period which expired on 31.03.2017. The assessee had fully disclosed all material facts regarding share capital receipts in the original return and financial statements. The AO failed to establish any failure by the assessee to disclose facts truly and fully, making the reopening invalid under the proviso to section 147. Case-Laws Income Tax Fri, 25 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=761828