Reopening assessments beyond four years barred where full and true disclosure eliminates omission to disclose material facts. Reopening an assessment beyond four years is permissible only if there was an omission to disclose material facts; where the assessee had fully and truly ... Summary
Reopening assessments beyond four years barred where full and true disclosure eliminates omission to disclose material facts.
Reopening an assessment beyond four years is permissible only if there was an omission to disclose material facts; where the assessee had fully and truly disclosed loan and interest details and the assessing officer merely sought a different view on deduction versus capitalization using the same material, the condition precedent for reopening under the proviso is not met and the notice to reopen cannot be sustained.
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TaxTMI 
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