https://www.taxtmi.com/caselaws?id=766715 The Bombay HC quashed a reassessment order u/s 147 for A.Y. 2014-15 issued beyond the mandatory four-year period. The court held that the assessing officer failed to establish that the assessee had not disclosed material facts fully and truly, as required under the proviso to Section 147. The reopening was based solely on documents and records already provided by the assessee during original assessment proceedings, lacking fresh tangible material. Additionally, the court found violation of natural justice principles under Section 144B, as the assessee's objections to reopening reasons were not considered, and no proper hearing was provided before passing the final order. The petition was allowed in favor of the assessee. en-us Thu, 27 Feb 2025 00:00:00 +0530 Thu, 14 May 2026 14:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=766715 The Bombay HC quashed a reassessment order u/s 147 for A.Y. 2014-15 issued beyond the mandatory four-year period. The court held that the assessing officer failed to establish that the assessee had not disclosed material facts fully and truly, as required under the proviso to Section 147. The reopening was based solely on documents and records already provided by the assessee during original assessment proceedings, lacking fresh tangible material. Additionally, the court found violation of natural justice principles under Section 144B, as the assessee's objections to reopening reasons were not considered, and no proper hearing was provided before passing the final order. The petition was allowed in favor of the assessee. Case-Laws Income Tax Thu, 27 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=766715