Mere incorrect claim based on full disclosures cannot be reassessed after four years

Tumkur Minerals Pvt. Ltd. Vs Joint Commissioner of Income Tax (Bombay High Court) This is a case where the Petitioner disclosed all material facts necessary for his assessment for AY 20 12-13. In the reasons furnished to the Petitioner, the AO omitted to point out the material facts, which according to him, the Petitioner had failed to disclose fully and truly. Since the disclosures were made in the annual accounts and audit reports, Explanation (1) to Section 147 of IT Act was not attracted. Besides, there is no dispute that the amount which the AO claims has escaped assessment during AY 2013...