Reassessment based on Documents already in hand of AO not Valid

DCIT Vs Sovereign Pharma Pvt. Ltd. (ITAT Pune) A bare perusal of reasons for reopening would show that the Assessing Officer has erred in invoking the provisions of section 148 r.w.s. 147 after the expiry of four years to cover up his own follies. It is not the case of Revenue that the assessee has not fully and truly disclosed all material facts necessary for its assessment. The proviso to section 147 mandates that the assessment can be reopened inter alia, where the assessee has failed to disclose fully and truly all material facts necessary for assessment for that assessment year. The provi...