Reassessment Quashed Due to No Failure to Disclose Material Facts

Chowgule & Company Pvt. Ltd. Vs JCIT (Bombay High Court) The Bombay High Court quashed the reassessment proceedings for Assessment Year (AY) 2012–13, holding that the notice issued under Section 148 of the Income-tax Act, 1961 on 29.03.2019 was without jurisdiction. The notice was issued after the expiry of four years from the end of the relevant AY, and therefore could be sustained only if there was a failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment. This legal position was not disputed by the Revenue. The reassessment was initi...