https://www.taxtmi.com/caselaws?id=770088 ITAT Delhi held that reassessment notice issued under section 148 beyond four years was time-barred and without jurisdiction. The AO's recorded reasons failed to allege non-disclosure of material facts by the assessee, which is prerequisite for invoking first proviso to section 147. The reasons incorrectly stated no assessment was carried out, contrary to facts. Without proper allegations of failure to disclose material facts, the notice lacked legal foundation. Consequently, the reassessment order and additions made thereunder were quashed. Assessee's appeal was allowed. en-us Fri, 02 May 2025 00:00:00 +0530 Tue, 06 May 2025 09:58:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=770088 ITAT Delhi held that reassessment notice issued under section 148 beyond four years was time-barred and without jurisdiction. The AO's recorded reasons failed to allege non-disclosure of material facts by the assessee, which is prerequisite for invoking first proviso to section 147. The reasons incorrectly stated no assessment was carried out, contrary to facts. Without proper allegations of failure to disclose material facts, the notice lacked legal foundation. Consequently, the reassessment order and additions made thereunder were quashed. Assessee's appeal was allowed. Case-Laws Income Tax Fri, 02 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=770088