Allowing the petition the Court held that the notice for reassessment had been issued after four years on the ground that the assessee had failed to disclose investments. It was not in dispute that the form of return of income, i. e., ITR-2, then in force had no separate column for the disclosure of any investment. The notice is held to be not valid. (AY. 2011-12)
Bhavik Bharatbhai Padia v. ITO (2019)419 ITR 149 (Guj.)(HC)
S. 147 : Reassessment-After the expiry of four years-No duty to disclose investments-Notice for failure to disclose investments is held to be not valid.[S. 148, Art. 226]