Reopening Beyond 4 Years Fails Without Assessee’s Default: ITAT Quashes 148 Notice

Avishkar Nirman Private Limited Vs ITO (ITAT Kolkata) ITAT Kolkata   allowed the appeal of Avishkar Nirman Private Ltd & quashed the reassessment proceedings for AY 2013-14 holding that the notice u/s 148 was issued beyond four years from the end of the relevant AY without alleging or establishing any failure on the part of the Assessee to disclose fully & truly all material facts. The original assessment was completed u/s 143(3) & the reopening was triggered solely on the basis of information received from the Investigation Wing relating to alleged accommodation entries. The Tri...