Reopening of assessment beyond 4 years unsustainable as full and true material facts disclosed

Crown Real Estate Pvt Ltd Vs ITO (ITAT Chennai)

ITAT Chennai held that reopening of assessment beyond 4 years without any failure on the part of the assessee to disclose fully and truly all material facts necessary for its assessment is bad in law and hence liable to be quashed.

Facts- The main contention of the appellant is assumption of jurisdiction u/s.148 of the Act by the AO and confirmed by the CIT(A) is against, for the reason that the reopening is beyond 4 years an

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