2015 (12) TMI 776 - SCH - Income Tax

Reopening of assessment - Held that - HC order upheld 2013 (3) TMI 645 - ALLAHABAD HIGH COURT In absence of any failure on the part of the petitioner to disclose fully and truly all material facts necessary for its assessment for the assessment years under consideration, the notice under section 148 of the Act having been issued after the expiry of a period of four years from the end of the relevant assessment years, the very initiation of proceedings under section 147 of the Act stand vitiated and as such cannot be sustained. - Decided in favour of assessee.