If assessee has made a full and true disclosure of all material facts for his assessment, action of re-opening assessment beyond a period of four years would stand barred

HIGH COURT OF BOMBAY, 3i Info tech Ltd. Vs. ACIT, APPEAL NO: W. P. No. 892 of 2010, ORAL JUDGMENT (Per Dr. D.Y. Chandrachud, J.) 1. Rule. With the consent of Counsel, rule is made returnable forthwith. By consent of Counsel for both the parties, the petition is taken up for hearing and final disposal. 2. The dispute in these proceedings arises out of a notice issued by the first respondent on 18 March 2009 by which an assessment for assessment year 2002-2003 is sought to be reopened in pursuance of the provisions of Section 147 of the Income Tax Act, 1961. The notice for reope...