Assessment cannot be Reopened if Assessee disclosed fully & Truly All Material Facts during Original Assessment

DCIT (LTU) Vs Gail (India) Ltd (ITAT Delhi) The issue under consideration is whether the AO is correct in re-opening of the assessment under section 147 even though the assessee has disclose fully and truly all the material facts during original assessment? ITAT states that the first proviso to section 147 provides that no action shall be taken under this section after the expiry of four years from the end of the relevant assessment year in cases where the original assessment was under s 143(3), unless the escapement is by reason of the failure on the part of the assessee to disclose fully and...