https://www.taxtmi.com/caselaws?id=762456 ITAT Kolkata held that reopening of assessment u/s 147 beyond four years was invalid. The AO issued notice u/s 148 based on information about accommodation entries from HDFC Bank account. However, the assessee had fully disclosed all material facts in the return filed u/s 139(1) and during scrutiny assessment u/s 143(3). The AO failed to record concrete findings regarding the assessee's failure to disclose material facts, which is mandatory for reopening beyond four years under the first proviso to section 147. The reassessment proceedings were declared null and void. Appeal allowed. en-us Thu, 28 Nov 2024 00:00:00 +0530 Sat, 30 Nov 2024 13:24:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762456 ITAT Kolkata held that reopening of assessment u/s 147 beyond four years was invalid. The AO issued notice u/s 148 based on information about accommodation entries from HDFC Bank account. However, the assessee had fully disclosed all material facts in the return filed u/s 139(1) and during scrutiny assessment u/s 143(3). The AO failed to record concrete findings regarding the assessee's failure to disclose material facts, which is mandatory for reopening beyond four years under the first proviso to section 147. The reassessment proceedings were declared null and void. Appeal allowed. Case-Laws Income Tax Thu, 28 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762456