Reopening Beyond 4 Years Quashed for No Failure Allegation

Anchor Alloys (P) ltd. Vs ACIT (ITAT Delhi) Mechanical 151 approval & no failure allegation: ITAT Delhi quashes reopening beyond 4 years  Delhi Tribunal  allowed the assessee’s appeal and quashed the reassessment proceedings initiated u/s 147. The Tribunal held that the reopening, initiated beyond four years from the end of the relevant assessment year, was invalid in law as the recorded reasons did not allege any failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment. It was noted that the issue of share application money had alread...