https://www.taxtmi.com/caselaws?id=767791 ITAT Pune quashed reassessment proceedings u/s 147 for AY 2011-12 as the notice was issued beyond four years without establishing failure by assessee to disclose material facts fully. The original assessment was completed u/s 143(3) and reasons recorded did not indicate non-disclosure by assessee. Court held reopening violated proviso to section 147 and was unlawful. Consequently, PCIT's revision order u/s 263 regarding accommodation entries and commission additions became infructuous and was dismissed. Appeal decided in favor of assessee. en-us Wed, 19 Feb 2025 00:00:00 +0530 Tue, 25 Mar 2025 08:48:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767791 ITAT Pune quashed reassessment proceedings u/s 147 for AY 2011-12 as the notice was issued beyond four years without establishing failure by assessee to disclose material facts fully. The original assessment was completed u/s 143(3) and reasons recorded did not indicate non-disclosure by assessee. Court held reopening violated proviso to section 147 and was unlawful. Consequently, PCIT's revision order u/s 263 regarding accommodation entries and commission additions became infructuous and was dismissed. Appeal decided in favor of assessee. Case-Laws Income Tax Wed, 19 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767791