Reassessment after 4 years not valid If Assessee Made Full & True Disclosure during original assessment

Ranjana Aggarwal Vs ITO (ITAT Delhi)

When the original assessment is completed u/s 143(3) and the reassessment proceedings have been initiated after a period of 4 years from the end of the relevant assessment year and there is no allegation of any failure on the part of the assessee to disclose fully and truly all material facts necessary for completion of the assessment, such reassessment proceedings initiated are void ab initio in view of the first proviso to Section 147.

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