Reopening u/s. 148 after four years without failure to disclose material facts unsustainable

Eurofins Peenya Resources Private Limited Vs DCIT (ITAT Bangalore) ITAT Bangalore held that reopening of assessment under section 148 after expiry of four years without failure on part of assessee to disclose fully and truly all material facts is invalid and hence liable to be quashed. Facts- The case of assessee was reopened u/s. 147 of the Act by issue of notice u/s. 148 on 31.3.2021. The main reason for reopening of the assessment is that the International Taxation Officer forwarded information that assessee has made payment of Rs.49,17,872 during the AY 2013-14 to a non-resident service pr...