In case of disclosure of material facts of during original assessment proceeding, AO cannot issue re-assessment notice u/s 148 of the Act to find nature of same

It is a settled position in law that for reassessment proceedings beyond the period of four years from the end of the relevant assessment year, it is an essential condition that the income chargeable to tax which has allegedly escaped assessment must be occasioned, inter alia, by reason of the failure on the part of the assessee to disclose fully and truly all material facts necessary for the assessment, for that assessment year. Mr Syali, the learned senior counsel, appearing on behalf of the petitioner / assessee submits that in the present case, this pre-condition has not been met, inasmuch...