Reassessment unsustainable if full & true material disclosure during original assessment

DCIT Vs Jan De Nul Dredging (I)(P) Ltd (ITAT Chennai) ITAT Chennai held that both the conditions u/s 147 of the Income Tax Act needs to be satisfied for initiation of re-assessment after four years from the end of the relevant assessment year. Here, as assessee has disclosed fully and truly all the material facts, re-assessment proceedings couldn’t be sustained. Facts- The case of the assessee was selected for scrutiny and notice u/s. 143(2) of the Act was issued and also notice u/s. 142(1) of the Act along with questionnaire was issued on 27.05.2013 and duly served on the assessee. In respo...