https://www.taxtmi.com/caselaws?id=460576 The ITAT Ahmedabad quashed the reopening of assessment under Section 147 after four years from the assessment year end. The tribunal held that the AO failed to record satisfaction that income escaped assessment due to the assessee's failure to disclose material facts truly and fully. Since the assessee had filed return under Section 139(1) and no additions were made during regular assessment, the successor AO's notice under Section 148 on the same issue amounted to exercising revisionary powers without valid grounds, making the reopening unsustainable in law. en-us Tue, 29 Aug 2023 00:00:00 +0530 Mon, 03 Feb 2025 13:30:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=460576 The ITAT Ahmedabad quashed the reopening of assessment under Section 147 after four years from the assessment year end. The tribunal held that the AO failed to record satisfaction that income escaped assessment due to the assessee's failure to disclose material facts truly and fully. Since the assessee had filed return under Section 139(1) and no additions were made during regular assessment, the successor AO's notice under Section 148 on the same issue amounted to exercising revisionary powers without valid grounds, making the reopening unsustainable in law. Case-Laws Income Tax Tue, 29 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=460576