Reopening after 4 years not permissible if all accounts & records were made available at the time of original assessment – HC

Delhi High Court held In the case of Consultating Engineering Services (India) Ltd. vs. DCIT that for reassessment as per first proviso of section 147, it is pre- condition that the assessee has not made a full and true disclosure of the material particulars necessary for the assessment. Accordingly, in the given case, the revenue cannot be permitted to reopen the assessment as the necessary pre-condition for doing so in a case which is beyond four years from the end of the relevant assessment year has not been fulfilled.

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