Reopening Tax Assessment Beyond Four Years Unjustified: No Evidence of Non-Disclosure by Assessee Found u/s 147.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Reopening of assessment u/s 147 - reopening beyond four years - the reopening of assessment u/s 147 in the present case, without any reference to failure on the part of the assessee to disclose all facts regarding the items in the return of income or books of account during the assessment proceeding, is not justified and is in violation to proviso to section 147. - AT....