No reopening if there was no failure on part of the petitioner to disclose true and full material facts during original assessment

HIGH COURT OF GUJARAT Vodafone West Ltd. versus Assistant Commissioner of Income-tax SPECIAL CIVIL APPLICATION NO. 16453 of 2012 MARCH 5, 2013 JUDGMENT Akil Kureshi, J. Heard learned counsel for the parties for final disposal of the petition. 2. The petitioner has challenged notice dated 7.3.2012 for reopening of assessment for the assessment year 2005-2006 which was previously framed by the Assessing Officer after scrutiny. Such notice thus was issued beyond a period of four years from the end of relevant assessment year. The Assessing Officer supplied his reasons recorded fo...