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Reassessment Notice Invalidated: No New Material Justifying Reopening Beyond Four Years u/s 148 of Income Tax Act.
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....Validity of reopening of assessment - notice beyond the period of four years - the very same material and the assessment records are sought to be revisited and therefore it is not the case of the authority that there was a failure to fully and truly disclose all facts that led to the escapement of income so as to warrant an exercise of reassessment u/s 148 of the Act. - HC....