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TMI Blog2021 (4) TMI 26X X X X Extracts X X X X X X X X Extracts X X X X ..... ction 148, it is clear that in the case of re-opening made beyond four years from the end of the relevant assessment year, it can only be resorted to in case of failure on the part of the assessee in disclosing, fully and truly, all material facts necessary for the assessment. However, this failure was not pointed out in the assessment order by the Assessing Officer. Therefore, it is clear that it ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s/2013 in respect of the assessment year 2004-05 on the file of the Income Tax Appellate Tribunal, Chennai, A Bench, the Revenue has filed the above appeal. 2.The appellant Revenue has raised the following substantial questions of law in the grounds of appeal: 1)Whether under the facts and circumstances of the case, the Hon'ble Income Tax Appellate Tribunal right in holding that the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... otice was issued on 28.03.2011 (i.e.) beyond the period of four years from the end of the relevant assessment year (i.e.) 31.03.2005. As per proviso to Section 148, it is clear that in the case of re-opening made beyond four years from the end of the relevant assessment year, it can only be resorted to in case of failure on the part of the assessee in disclosing, fully and truly, all material fact ..... X X X X Extracts X X X X X X X X Extracts X X X X
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