https://www.taxtmi.com/caselaws?id=782193 ITAT Raipur held that reassessment proceedings initiated u/s 147/148 were invalid as the notices were issued beyond four years from the end of the relevant assessment years without demonstrating any failure by the assessee to fully and truly disclose all material facts. The A.O. did not record any specific failure regarding evaporation/handling loss of petrol or diesel, nor correlate it with IOC guidelines as required under the 1st proviso to s.147. Relying on HC precedent in Hariom Ingots and Power, ITAT quashed the reassessments as void ab initio, rendering all consequential proceedings non est. en-us Mon, 28 Jul 2025 00:00:00 +0530 Wed, 26 Nov 2025 08:43:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=782193 ITAT Raipur held that reassessment proceedings initiated u/s 147/148 were invalid as the notices were issued beyond four years from the end of the relevant assessment years without demonstrating any failure by the assessee to fully and truly disclose all material facts. The A.O. did not record any specific failure regarding evaporation/handling loss of petrol or diesel, nor correlate it with IOC guidelines as required under the 1st proviso to s.147. Relying on HC precedent in Hariom Ingots and Power, ITAT quashed the reassessments as void ab initio, rendering all consequential proceedings non est. Case-Laws Income Tax Mon, 28 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=782193