Reopening beyond 4 years is bad in law if all primary facts disclosed during original assessment proceedings

Harsh Kaushal Corporation Vs ITO (Bombay High Court) In the present case, it is evident from the reasons recorded for reopening that the petitioner had truly and fully disclosed all material facts necessary for the purpose of assessment. In fact, in the reasons for reopening, there is not even a whisper as to what was not disclosed. The Assessing Officer has relied upon the records filed by petitioner including the profit and loss account and balancesheet and says from those records it is revealed that there is closing stock in trade of Rs.33,49,89,003/-. Therefore, the respondent No.1 is rely...