No reopening of Assessment after 4 Year if no failure of Assessee in disclosing relevant facts

CIT Vs Sterling Tree Magnum India Ltd. (Madras High Court) Learned Tribunal has categorically held that there was no failure on the part of the assessee, but disclosed the relevant facts and therefore, merely on the basis of the audit objection or change of opinion and re-assessment under Sections 147 & 148 of the Income Tax Act, 1961, could not be made beyond the period of four years from the end of the relevant assessment year 1997-98. In the present case, the notice under Section 148 of the Income Tax Act, 1961, was issued on 26.03.2004, as per the assessment order much beyond the perio...