No reassessment after 4 years in case there was no disclosure failure on the part of assessee

PCIT Vs SKI Retail Capital Ltd. (Madras High Court) Conclusion: AO was not justified in reopening of assessment after four years as on an independent application of mind and on thorough consideration of material aspects and legal position,there was no failure on the part of assessee. Held: AO reopened case under Section 147 by the issuance of notice under section 148 and in response to the same, assessee had sent a letter stating that the return of Income already filed by him be treated as Return filed by him in compliance with Notice. AO after considering and scrutinizing the materials, had t...