ITAT Chandigarh Quashed Reassessment Beyond Four Years for No Disclosure Failure

ITAT Chandigarh: Reassessment set aside as void ab initio on account of limitation; breach of CBDT instructions held not to vitiate the notice issued under section 143(2) The Income Tax Appellate Tribunal, Chandigarh quashed the reassessment and deleted the addition made against a manufacturing company where reopening was based solely on an unverified third-party excel sheet recovered during a search on another entity. The Tribunal held that reopening beyond four years was invalid as there was no allegation or finding of failure by the assessee to disclose fully and truly all material facts in...