https://www.taxtmi.com/caselaws?id=464244 HC upheld the Tribunal and dismissed the Department's challenge, holding reassessment under s.147 (proviso) invalid. The court found the assessee had "fully and truly" disclosed material facts by placing and claiming relief under the relevant administrative Circular, which the AO had considered and acted upon in the original s.143(3) assessment. A later characterization of the taxpayer's profession as "professional" in subsequent years did not prove concealment for the year in question. Because material facts were before the tax authorities, the proviso to s.147 could not lawfully justify reopening, and the reassessment was quashed. en-us Thu, 21 Aug 2008 00:00:00 +0530 Tue, 14 Oct 2025 12:52:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=464244 HC upheld the Tribunal and dismissed the Department's challenge, holding reassessment under s.147 (proviso) invalid. The court found the assessee had "fully and truly" disclosed material facts by placing and claiming relief under the relevant administrative Circular, which the AO had considered and acted upon in the original s.143(3) assessment. A later characterization of the taxpayer's profession as "professional" in subsequent years did not prove concealment for the year in question. Because material facts were before the tax authorities, the proviso to s.147 could not lawfully justify reopening, and the reassessment was quashed. Case-Laws Income Tax Thu, 21 Aug 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=464244