Held that the Assessing Officer has not alleged that the assessee had failed to fully and truly discloser of all material facts. It is for the for the Revenue to establish that the failure to disclose material facts. Accordingly the reassessment is quashed.(AY. 2013-14)
Anchita Properties P. Ltd. v. ITO (2024)115 ITR 401 (Kol)(Trib)
S.147: Reassessment-After the expiry of four years-Investments-No failure to disclose material facts-Onus on revenue-Reassessment notice and order is quashed. [S. 143(3). 148]