Reassessment after 4 years without failure to disclose full & true material facts unsustainable

Rajshree Realtors Private Limited Vs Union of India (Bombay High Court) Bombay High Court held that initiation of reassessment proceedings u/s 147 after the expiry of 4 years from the end of the relevant assessment years without failure on the part of the assessee to disclose fully and truly all the material facts unsustainable and liable to be quashed. Facts- During the assessment proceedings, AO made addition of Rs. 3,00,00,000/- u/s. 68. However, CIT(A) deleted the said addition. ITAT upheld the order of the CIT(A). Accordingly, revenue has challenged the order of ITAT and appeal is still p...