Reassessment Beyond 4 Years Quashed – ITAT Says AO Must Specifically Allege Failure to Disclose Material Facts

Fashion Accessories Vs DCIT (ITAT Delhi) The Delhi ITAT quashed reassessment proceedings initiated against M/s. Fashion Accessories for AYs 2011-12 and 2012-13, holding that reopening beyond four years from the end of the assessment year was invalid since the Assessing Officer failed to record any allegation regarding failure of the assessee to make full and true disclosure of material facts. The reassessment was initiated on the basis of information received from another officer alleging that an employee of the assessee had stated that no actual business activity was being carried on. However...