Held that there was no mention of the failure on the part of the assessee to make a full and true disclosure of all material facts relevant for the purpose of assessment in the original assessment proceedings before the Assessing Officer. According to the proviso, the Assessing Officer was bound to mention the failure on the part of the assessee to make a full and true disclosure of all material facts relevant for the purpose of assessment. The Assessing Officer had invalidly assumed the jurisdiction under section 147 of the Act. Hence, the reassessment order is quashed.(AY.2008-09)
Asst. CIT (OSD) v. S. S. Gas Lab Asia P. Ltd. (2023)107 ITR 482 (Delhi) (Trib)
S. 147 : Reassessment-After the expiry of four years-No failure to disclose material facts-Reassessment is quashed. [S. 148]