Bhoomi Construction Projects v. ITO (2024) 469 ITR 547 (Bom)(HC)

S.147: Reassessment-After the expiry of four years-No failure to disclose material facts-Reassessment is not valid. [S. 148, Art. 226]

Held, that no specific reasons were given nor was there discovery of new material in the reasons to show a failure on the part of the assessee to disclose material facts necessary for assessment. Moreover, a query was raised with regard to the sale of the shop and the details were called for and the queries were answered by the assessee. The notice of reassessment dated March 29, 2021 and the order dated February 17, 2022 were quashed. (AY.2013-14)

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