Tax Reassessment Under Section 147 Invalid When No Material Facts Were Concealed And 4-Year Period Expired

HC quashed reassessment proceedings initiated under Section 147 after expiry of 4-year limitation period. Court found no failure by assessee to disclose material facts fully and truly, as required by first proviso to Section 147. Information relied upon for reopening was already available in documents filed with return and during original assessment. Where matter was previously examined during assessment after raising queries, allowing reassessment would amount to impermissible review power. Reopening notice held invalid as reasons recorded failed to specify any non-disclosure of material facts by assessee. .....

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