No reassessment after four years in absence of failure to disclosures by assessee

Jayesh T Kotak  Vs DCIT (Gujarat High Court)

Conclusion: In the absence of failure on the part of assesse to disclose fully and truly all material facts necessary for his assessment, the reopening of assessment beyond a period of four years from the end of relevant assessment year was without authority of law.

Held: AO reopened assessment by issuing notice under section 148 after a gap of more than four years. Assessee contended that  he had filed all pr

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