https://www.taxtmi.com/caselaws?id=766828 The ITAT Mumbai held that reassessment proceedings initiated after four years regarding disallowance of car hire charges were invalid. The tribunal found that the AO's recorded reasons failed to establish that the assessee had not disclosed material facts fully and truly. During original assessment proceedings, the assessee had responded to specific queries about vehicle hiring charges, provided justification letters, and submitted vehicle hiring agreements. Since Section 147 proviso requires failure to disclose material facts for reopening after four years, and no such failure was demonstrated in the recorded reasons, the reassessment proceedings were held bad in law. The assessee's appeal was allowed. en-us Mon, 10 Feb 2025 00:00:00 +0530 Wed, 05 Mar 2025 07:49:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=766828 The ITAT Mumbai held that reassessment proceedings initiated after four years regarding disallowance of car hire charges were invalid. The tribunal found that the AO's recorded reasons failed to establish that the assessee had not disclosed material facts fully and truly. During original assessment proceedings, the assessee had responded to specific queries about vehicle hiring charges, provided justification letters, and submitted vehicle hiring agreements. Since Section 147 proviso requires failure to disclose material facts for reopening after four years, and no such failure was demonstrated in the recorded reasons, the reassessment proceedings were held bad in law. The assessee's appeal was allowed. Case-Laws Income Tax Mon, 10 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=766828