Reassessment after 4 year invalid if assessee disclosed all material facts during original assessment

CIT Vs Mr. John Ettimootil Samuel (Madras High Court)

1. Sets aside reassessment framed u/s 147 after expiry of four years of assessment u/s 143(3), holding that the assessee had disclosed all material facts in the original assessment qua consideration and deemed consideration u/s 50C of the Act.

2. The Tribunal was fully justified in holding that the reopening of the assessment could not have been made in the facts and circumstances of the case and we find no question of law, much less substantial qu

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