https://www.taxtmi.com/caselaws?id=773874 The ITAT Delhi quashed reopening proceedings under Section 147 initiated after four years from the assessment year. The tribunal held that where an assessment under Section 153A has been completed and the four-year limitation period has expired, reopening can only occur if the assessee failed to disclose material facts fully and truly. Since the AO failed to record reasons establishing such non-disclosure in the case, the entire reopening proceeding was vitiated and quashed. en-us Fri, 16 May 2025 00:00:00 +0530 Mon, 30 Jun 2025 08:43:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=773874 The ITAT Delhi quashed reopening proceedings under Section 147 initiated after four years from the assessment year. The tribunal held that where an assessment under Section 153A has been completed and the four-year limitation period has expired, reopening can only occur if the assessee failed to disclose material facts fully and truly. Since the AO failed to record reasons establishing such non-disclosure in the case, the entire reopening proceeding was vitiated and quashed. Case-Laws Income Tax Fri, 16 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=773874