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 primary documents which were statutorily required to be filed along with the return of income and had also filed all documents that were calle...