Reopening after expiry of four years invalid if there was no failure on the part of assessee

Garg Zevar Palace Pvt. Ltd Vs ITO (ITAT Delhi)

Section 147 mandates that the case can only be reopened after expiry of four years only if there was a failure on the part of the assessee to fully and truly disclose all material facts necessary. The assessee has disclosed the fact of receipt of Rs.60,00,000/- towards the share capital in the regular return filed which has been scrutinized u/s 143(3). In the reasons recorded for reopening, the Assessing Officer has not mentioned anything with regard to failure on the part of th

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