Anil Raj Tuli v. ITO(NFAC) (2023)454 ITR 411/ 330 CTR 582/ 221 DTR 390 (Orissa)(HC)

S. 147 : Reassessment-After the expiry of four years-No new material and no evidence of non-disclosure of facts-Notice and order disposing the objection was quashed. [S. 148, Art. 226]

Allowing the petition the Court held that the assessee had produced the complete books of account, which were perused by the Income-tax Officer.. There was application of mind by the Income-tax Officer to the materials produced by the assessee. The reopening of the assessment was based on the same material already available before the Assessing Officer and without any noting, at the time of reopening of the assessment that there was a failure on the part of the assessee to make a full and true disclosure of all material particulars. The notice and the order disposing the objection was quashed. (AY. 2014-15)