Mere assertion of "failure to disclose fully and truly all material facts" does not confer jurisdiction...

Mere assertion of "failure to disclose fully and truly all material facts" does not confer jurisdiction for reopening assessment beyond four years. AO must demonstrate assessee's specific failure. Here, assessee duly disclosed sundry creditors and sales details during original assessment proceedings, which AO accepted. Lapse of time alone cannot be deemed cessation of liability or justify reopening. AO cannot draw new inferences without contrary material. Reopening quashed as reasons recorded lack jurisdiction beyond four years from relevant assessment year. Reassessment order quashed. Appeal allowed. .....

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