Reassessment u/s 147 for TDS non-deduction ruled unsustainable; initiated beyond four years despite full disclosure.

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....Reopening of assessment u/s 147 - non-deduction of TDS as mentioned in the Form no. 3CD Tax Audit Report u/sec. 44AB - the assessee has filed the details and disclosed fully and truly all material facts relevant to the assessment year in consideration. - the assessment was reopened beyond a period of four years and cannot be sustained. - AT....