Reopening Tax Assessment Invalid Without Alleged Disclosure Failure, Violates Section 147 if Beyond Four Years.

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....Reopening of assessment u/s 147 - reasons to believe - bogus transaction - It has been held that even in the reasons recorded when there is no allegation that there was any failure on the part of the assessee in not disclosing truly and fully material facts necessary for the assessment, the assumption of jurisdiction to reopen the assessment beyond a period of four years in exercise of powers under Section 147 of the Act is bad in law and contrary to the provisions of Section 137. - HC....