Reopening beyond 4 years without any failure in disclosing material facts unsustainable

DCIT Vs Santha Build Tech India Pvt. Ltd. (ITAT Chennai) ITAT Chennai held that reopening after expiry of 4 years, without establishing any failure on part of the assessee to disclose any material facts necessary for its assessment, is bad-in-law and liable to be quashed. Facts- The assessee is engaged in the business of construction of residential buildings. The assessee’s case was selected for scrutiny assessment and the assessment was completed u/s. 143(3) of the Act vide order dated 31.03.2016. Subsequently, assessment framed was reopened u/s.147 of the Act by issuing notice u/s.148 of t...