Merely reason to believe not sufficient to reopen assessments beyond 4 year period

Amrabathi Investra (P) Ltd. Vs ITO (ITAT Kolkata) In the assessee`s case in the reasons supplied to the assesseee, as noted in above para, there is no whisper, what to speak of any allegation, that the assessee had failed to disclose fully and truly all material facts necessary for assessment and that because of this failure there has been an escapement of income chargeable to tax. Merely having a reason to believe that income had escaped assessment, is not sufficient to reopen assessments beyond the four year period, as explained above. The escapement of income from assessment must also be oc...