https://www.taxtmi.com/caselaws?id=780931 ITAT Raipur held that reassessment issued u/s 148/147 beyond four years was invalid where the AO had not recorded satisfaction under the 1st proviso to s.147 showing failure to disclose material facts. The AO also failed to furnish documents/information relied upon, breaching principles of natural justice as emphasized by Bombay HC guidance. Reopening beyond four years without requisite satisfaction and without sharing relied materials rendered the reassessment arbitrary and void ab initio. The reassessment notice/order was quashed and the assessee's appeal allowed. en-us Mon, 25 Aug 2025 00:00:00 +0530 Sat, 08 Nov 2025 08:30:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780931 ITAT Raipur held that reassessment issued u/s 148/147 beyond four years was invalid where the AO had not recorded satisfaction under the 1st proviso to s.147 showing failure to disclose material facts. The AO also failed to furnish documents/information relied upon, breaching principles of natural justice as emphasized by Bombay HC guidance. Reopening beyond four years without requisite satisfaction and without sharing relied materials rendered the reassessment arbitrary and void ab initio. The reassessment notice/order was quashed and the assessee's appeal allowed. Case-Laws Income Tax Mon, 25 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780931