Validity of Reopening Assessment Beyond Four-Year Limitation Period Hinges on Assessee’s Full Disclosure

Prime Developers Vs ACIT (ITAT Mumbai)

Reopening of assessment beyond four-year limitation period invalid if AO fails to establish failure on the part of Assessee to fully and truly disclose all material facts necessary for assessment.

Prime Developers had undergone a regular scrutiny assessment under section 143(3) for the assessment year 2011-12, concluded on March 21, 2014. Subsequently, a notice under section 148 was issued on March 27, 2018, beyond the four-year limitation period specified in the first proviso to Section 147. The issue in question was whether there was

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