Foreign Office Expenses Disallowed Without New Evidence; Reassessment Beyond Four Years Lacks Proof of Assessee's Fault.

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....Disallowance of running and maintenance expenses of foreign office - This amount has been duly disclosed in the audited financial statements and no fresh material on the issue has been brought on record by the Assessing Officer. Undisputedly, the reassessment is beyond the period of four years and, therefore, it was incumbent upon the Assessing Officer to point out specifically as to how the escapement of income from tax on this issue could be attributed to any fault on the part of the assessee. - AT....