No allegation of failure on the part of the assessee to disclose all the material facts for completion of assessment. The Assessing Officer had not satisfied the twin conditions needed under section 147 for reassessment. The reassessment order held to be bad in law. (AY.2010-11)
ACIT v. AbirInfrastructure Pvt. Ltd. (2022)97 ITR 245 (Hyd.) (Trib)
S. 147 : Reassessment-With in four years-No failure of disclosure of facts-Reassessment order is bad in law. [S. 148]