Reopening of assessment beyond a period of 4 years to make fishing inquiries not justified

Crescent Construction Co. Vs. Asst. CIT (ITAT Mumbai) Under the new provisions of section 147, an assessment can be reopened if the assessing officer has “reason to believe” that income chargeable to tax has escaped assessment; but if he wants to do so after a period of four years from the end of the assessment year, he can do so only if the assessee has fallen short of his duty to disclose fully and truly all material facts necessary for his assessment. It does not follow that he cannot reopen the assessment even within the period of four years as aforesaid if he has reason to believe tha...