Reassessment Quashed: Failure to Show Taxpayer's Incomplete Disclosure u/s 148 Invalidates Reopening After Four Years.

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....Reassessment u/s 148 - reasons recorded should show in what manner the assessee had failed to make a full and true disclosure of all material facts necessary for the assessment, it is not mere irregularity but it would render the reopening of assessment after four year invalid as First proviso to section 147 is applicable - assessment quashed....