ITAT Ranchi Quashed Reassessment Beyond Four Years for No Disclosure Failure

Colen Chemical Pvt. Ltd. Vs ITO (ITAT Ranchi) Beyond Four Years, Silence Is Fatal: ITAT Ranchi Quashes Reopening for Want of ‘Failure to Disclose’ The ITAT Ranchi allowed the assessee’s appeals for AYs 2013–14 and 2014–15, quashing the reassessment proceedings initiated under sections 147/148 after the expiry of four years from the end of the relevant assessment years. In both years, the original assessments had been completed under section 143(3). The Tribunal noted that where reopening is sought beyond four years, the proviso to section 147 mandates a clear and specific allegation ...