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TMI Blog2014 (5) TMI 13X X X X Extracts X X X X X X X X Extracts X X X X ..... 005 – also, the proposal to reopen is beyond the period of four years – Decided in favour of Assessee. - WRIT PETITION NO.2349 OF 2011 - - - Dated:- 4-4-2014 - S.J. VAZIFDAR B.P. COLABAWALLA, JJ. For the Petitioner : Mr. Jitendra Jain with Mr.B.D. Damodar i/b M/s.Kanga Co. For the Respondent : Mr.Vimal Gupta, Senior Counsel with Ms.Padma Divakar P.C. :- 1. Rule. Rule is ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Assessing Officer by a letter dated 10.07.2006 required the petitioner to furnish the details, including the details of the long term capital gain and short term capital loss along with evidence for the same, as a well as a copy of the capital account for the period 01.04.2003 to 31.03.2003. The petitioner admittedly furnished the same under cover of a letter dated 24.07.2006. Paragraphs 1 and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ontain even a whisper to the effect that the petitioner had failed to disclose fully and truly all material facts necessary in the assessment of AY 2004-2005. This was necessary, as the proposal to reopen is beyond the period of four years after the end of the assessment year in question. 6. Mr. Gupta contended that the reasons read as a whole indicate the same. 7. We do not agree. The reaso ..... X X X X Extracts X X X X X X X X Extracts X X X X
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