Reassessment Invalid After Four Years Without Non-Disclosure Evidence, Tribunal Rules in Favor of Taxpayer.

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....The Appellate Tribunal examined the reopening of assessment after four years and the addition u/s 68 of the Income Tax Act. It held that the original assessment was completed on 27.11.2018, and the notice u/s 148 for reopening was issued on 22.03.2019, after the expiry of the four-year period from the end of the assessment year 2011-12. The assessee had disclosed the information regarding the receipt of share capital in the return and financial statements during the original assessment. The Assessing Officer failed to substantiate any fault on the assessee's part in fully and truly disclosing material facts. Relying on the Bombay High Court's decisions in Everest Kanto Cylinder Ltd. and Ananta Landmark (P) Ltd., the Tribunal held that after.........