https://www.taxtmi.com/caselaws?id=460626 The ITAT Kolkata quashed the reopening of assessment under section 147 beyond four years. The assessee had disclosed capital loss from share trading, and the Assessing Officer failed to establish that income escaped assessment due to non-disclosure of material facts. The tribunal found the reopening violated the First Proviso to section 147, as there was no allegation of failure to disclose material facts. The notice under section 148 was deemed bad in law since the AO did not properly apply his mind to the information received. All additions made during the reassessment were deleted, ruling in favor of the assessee. en-us Mon, 19 Feb 2024 00:00:00 +0530 Thu, 06 Feb 2025 18:58:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=460626 The ITAT Kolkata quashed the reopening of assessment under section 147 beyond four years. The assessee had disclosed capital loss from share trading, and the Assessing Officer failed to establish that income escaped assessment due to non-disclosure of material facts. The tribunal found the reopening violated the First Proviso to section 147, as there was no allegation of failure to disclose material facts. The notice under section 148 was deemed bad in law since the AO did not properly apply his mind to the information received. All additions made during the reassessment were deleted, ruling in favor of the assessee. Case-Laws Income Tax Mon, 19 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=460626