Gujarat HC Quashes Reopening Beyond Four Years for Lack of Non-Disclosure & Borrowed Satisfaction

Harikishan Sunderlal Virmani Vs DCIT (Gujarat High Court) Gujarat High Court has quashed a reassessment notice issued by the Deputy Commissioner of Income Tax (DCIT) against Harikishan Sunderlal Virmani for the Assessment Year 2009-2010. The court found that the re-opening of the assessment, initiated beyond the four-year statutory period, lacked evidence of the assessee’s failure to fully disclose material facts and was based on “borrowed satisfaction” rather than an independent opinion formed by the Assessing Officer (AO). The case, Harikishan Sunderlal Virmani Vs DCIT, ste...