Reopening notice beyond four years cannot be sustained without non-disclosure

CIT Vs Siva Ventures Ltd (Madras High Court) The Madras High Court has dismissed an appeal filed by the Commissioner of Income Tax (CIT) against Siva Ventures Ltd., upholding the Income Tax Appellate Tribunal’s decision to quash reassessment proceedings initiated by the Revenue. The core issue revolved around whether there was a failure on the part of the assessee to fully and truly disclose material facts during the original assessment, a prerequisite for reopening assessments beyond four years. The case stemmed from an assessment order passed under Section 143(3) of the Income Tax Act....