https://www.taxtmi.com/caselaws?id=774228 ITAT Delhi allowed the assessee's appeal and upheld CIT(A)'s order quashing the reopening of assessment under section 147 beyond four years. The AO failed to establish two essential conditions: the assessee's failure to fully disclose material facts and actual escapement of income. The tribunal found that expenditure of Rs. 60 crores for actor rights was recorded as both expenditure and stock-in-trade, creating revenue-neutral contra entries. Without demonstrating income escapement, the reassessment lacked jurisdictional validity, following the Givaudan Flavours precedent. en-us Fri, 30 May 2025 00:00:00 +0530 Sat, 05 Jul 2025 08:47:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774228 ITAT Delhi allowed the assessee's appeal and upheld CIT(A)'s order quashing the reopening of assessment under section 147 beyond four years. The AO failed to establish two essential conditions: the assessee's failure to fully disclose material facts and actual escapement of income. The tribunal found that expenditure of Rs. 60 crores for actor rights was recorded as both expenditure and stock-in-trade, creating revenue-neutral contra entries. Without demonstrating income escapement, the reassessment lacked jurisdictional validity, following the Givaudan Flavours precedent. Case-Laws Income Tax Fri, 30 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774228