Reopening Beyond Four Years Invalid as Non-Filing of Form 3CL Not Material Non-Disclosure

Apollo Tyres Ltd Vs ACIT (Kerala High Court)

Reopening of assessment beyond four years was unsustainable as non-filing of Form 3CL did not constitute non-disclosure of material facts.

Conclusion: Form 3CL was not a determinative document for claiming deduction, and non-production of the same did not amount to wilful non-disclosure or suppression of material facts under Explanation 1 to Section 147. The reopening of assessment beyond four years was there

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