Duty of AO in case of Reassessment after 4 Year of original assessment

AO bound to demonstrate that the assessee has failed to disclose material facts fully and truly which has resulted in escapement of income. If he fails to demonstrate this aspect, then, in the case where scrutiny assessment has been made and four years have expired, he cannot take action under section 147 of the Income Tax Act. The ld.DR relied upon the order of the AO and submitted that the ld.AO has rightly recorded reasons that the assessee has claimed excessive short term capital loss which was not admissible to the assessee. On the other hand, the ld.counsel for the assessee contended tha...