Reopening Tax Assessments: Section 147 Requires Full Disclosure Failure for Beyond Four-Year Reassessment.

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....Reopening of assessment u/s 147 - Reasons for belief that income has escaped assessment - Merely having a reason to believe that income had escaped assessment, is not sufficient to reopen assessments beyond the four year period, as explained above. The escapement of income from assessment must also be occasioned by the failure on the part of the assessee to disclose material facts, fully and truly. - AT....