AO can initiate reassessment if excess deduction was allowed based on wrong information supplied to it

Aircel Cellular Limited Vs DCIT (Madras High Court) Legal provisions involved As per first proviso to Section 147 where assessment has already been made under Section 143(3) and assessee had disclosed truly and fully all material facts necessary for assessment then AO cannot initiate reassessment proceedings under Section 147 beyond 4 years from end of relevant A.Y. In section 147 the expression ‘true and full disclosure’ is not been defined. Madras High Court in the given judicial precedent has attempted to elaborate the circumstances in which it can be construed that there is no ...