Reassessment Beyond Four Years: Failure to Disclose Material Facts is Essential – Bombay HC

First Source Solutions Limited Vs ACIT (Bombay High Court)

The case concerns First Source Solutions Ltd. challenging a notice issued under Section 148 of the Income Tax Act, 1961, seeking to reopen the assessment for the year 2012-13. The Income Tax Department argued that the company’s short-term capital gains of ₹9.42 crore were wrongly included in the computation for deduction under Section 10AA. The reassessment notice, issued after four years, alleged that income had escaped assessment due to the company’s failure to fully disclose relevant facts. However, the petitioner

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