Reassessment beyond four years is invalid if no failure to disclosure by Assessee during original assessment

S. Ramamirtham Vs ITO (ITAT Chennai) It is an admitted fact that the original assessment has been completed u/s. 143(3) of the Act on 20.03.2014. It is also an admitted fact that notice u/s. 148 of the Act dated 13.09.2017 is beyond four years from the end of the relevant assessment year. Thus, proviso to section 147 of the Act would come into operation, and as per said proviso, where the assessment under sub section (3) of section 143 has been made for the relevant assessment year, no action shall be taken under this section after the expiry of four years from the end of the relevant assessme...