ITAT Delhi Quashes Reassessment Beyond Four Years for Lack of Disclosure Failure

Ram Fashion Exports Private Limited Vs DCIT (ITAT Chennai) Reassessment Beyond Four Years Invalid in Absence of Failure to Fully and Truly Disclose Material Facts – Mere Change of Opinion Not Permissible The appellant is an exporter of leather footwear. It filed IT return for AY 2013-14 on 29.09.2013. The return was selected for scrutiny under section 142(1) and (2). It replied. Assessing officer passed assessment order under section 143(3) accepting the returned income (but for minor variation). However; notice under section 148 was issued; after expiry of four years; on 14.03.2019. The rea...