Reopening beyond 4 years of assessment u/s 143(3) without allegation of non-disclosure is untenable

Gokaldas Exports Vs DCIT (ITAT Bangalore) ITAT Bangalore held that reopening beyond the period of 4 years of completion of assessment u/s 143(3) without allegation regarding non-disclosure of full and true material facts is bad-in-law. Facts- The case was selected for scrutiny and statutory notices were issued to the assessee. In response to the notice assessee filed details. After considering the submissions of the assessee the Assessing Officer (AO) passed order under Section 143(3) of the Act on 15.03.1998. The case was reopened under Section 147/148 of the Act by issuing notice dated 30.07...