https://www.taxtmi.com/caselaws?id=460958 The ITAT Mumbai held that reassessment proceedings initiated beyond the four-year limitation period were invalid. The revenue disallowed car hire charges as unjustified and violative of fiduciary relationship between trust and trustee. However, the tribunal found that the assessee had disclosed all material facts during original assessment proceedings, including filing justification letter and vehicle hiring agreement in response to specific queries. Since the reasons recorded did not establish failure to disclose material facts fully and truly as required under Section 147 proviso, the reassessment proceedings were held bad in law. Appeal allowed. en-us Thu, 28 Nov 2024 00:00:00 +0530 Tue, 04 Mar 2025 18:58:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=460958 The ITAT Mumbai held that reassessment proceedings initiated beyond the four-year limitation period were invalid. The revenue disallowed car hire charges as unjustified and violative of fiduciary relationship between trust and trustee. However, the tribunal found that the assessee had disclosed all material facts during original assessment proceedings, including filing justification letter and vehicle hiring agreement in response to specific queries. Since the reasons recorded did not establish failure to disclose material facts fully and truly as required under Section 147 proviso, the reassessment proceedings were held bad in law. Appeal allowed. Case-Laws Income Tax Thu, 28 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=460958