https://www.taxtmi.com/caselaws?id=781185 ITAT held that reassessment beyond four years was invalid where the AO failed to allege that income escaped due to the assessee's failure to disclose fully and truly all material facts as required by the first proviso to s.147. The TPO and AO had earlier accepted the return and Form 3CEB entries (including reimbursements) and raised no objection; the reasons for reopening did not satisfy the proviso. Reopening for AY 2007-08 was without jurisdiction and the appeal was allowed, assessment quashed. en-us Mon, 10 Nov 2025 00:00:00 +0530 Wed, 12 Nov 2025 08:17:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=781185 ITAT held that reassessment beyond four years was invalid where the AO failed to allege that income escaped due to the assessee's failure to disclose fully and truly all material facts as required by the first proviso to s.147. The TPO and AO had earlier accepted the return and Form 3CEB entries (including reimbursements) and raised no objection; the reasons for reopening did not satisfy the proviso. Reopening for AY 2007-08 was without jurisdiction and the appeal was allowed, assessment quashed. Case-Laws Income Tax Mon, 10 Nov 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=781185