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

Brief of the Case 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. Facts of the Case The assessment of the assessee was c...