Reopening beyond 4 years without new material facts not sustainable in law: Gujarat HC

PCIT Vs IOT Anwesha Engineering And Projects Ltd. (Gujarat High Court) Gujarat High Court held that in the absence of new material facts brought on record by the Revenue reopening of assessment beyond the period of 4 years is found to be not sustainable in the eye of law. Thus, appeal of revenue dismissed. Facts- The assessee e-filed its Return of Income declaring total income Rs. 2,67,91,420/-, which was initially assessed u/s 143(3) of the Act dated 29.11.2011. The assessment was finalized determining the total income at Rs. 2,69,50,080/- and subsequently revised at Rs. 2,67,91,420/- on 03.1...