https://www.taxtmi.com/caselaws?id=769582 The Bombay HC dismissed a petition challenging reassessment proceedings initiated under Section 147 after four years. The petitioner received loans from entities in Cyprus and Mauritius through circuitous routes, which the revenue discovered post-assessment through intelligence. The Court held that failure to disclose material facts can be inferred from recorded reasons even without explicit statement. The circuitous movement of funds through tax haven entities constituted non-disclosure of material facts. The Court ruled that subsequent discovery of bogus transactions validates reassessment jurisdiction, and the petitioner's reference to Income Tax Settlement Commission proceedings for a different assessment year was irrelevant. en-us Fri, 25 Apr 2025 00:00:00 +0530 Mon, 28 Apr 2025 08:35:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=769582 The Bombay HC dismissed a petition challenging reassessment proceedings initiated under Section 147 after four years. The petitioner received loans from entities in Cyprus and Mauritius through circuitous routes, which the revenue discovered post-assessment through intelligence. The Court held that failure to disclose material facts can be inferred from recorded reasons even without explicit statement. The circuitous movement of funds through tax haven entities constituted non-disclosure of material facts. The Court ruled that subsequent discovery of bogus transactions validates reassessment jurisdiction, and the petitioner's reference to Income Tax Settlement Commission proceedings for a different assessment year was irrelevant. Case-Laws Income Tax Fri, 25 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=769582