Reopening of assessment u/s 148 unjustified as all material facts fully disclosed

S. Uttam Chand Vs ACIT (Madras High Court) Madras High Court held that reopening of assessment u/s 148 of the Income Tax Act beyond the period of four years unjustified as all the particulars with regard to sale of agricultural land was disclosed before AO in full extent. Facts- The case of the petitioner was that the present notice issued u/s. 147 of the Income Tax Act was beyond the period of four years stipulated in the Act since the impugned notice was issued on 30.03.2021 whereas the issue pertains to A.Y. 2013-­2014. In terms of proviso to Section 147, the limitation period is four year...