Allowing the petition there was no failure on the part of the assessee to fully and truly disclose all material facts before the Assessing Officer. The Assessing Officer had sought to reopen the assessment from the material already produced on record and did not have any new or tangible material in his possession. The notice issued under section 148 is quashed and set aside. (AY. 2014-15)
Dediyasan Industrial Co-Op, Credit Society Ltd. v. Dy. CIT (2025) 473 ITR 347 (Guj)(HC)
S.147: Reassessment-After the expiry of four years-Change of opinion-Fixed deposit interest-No failure to disclose material facts-Reassessment notice and order disposing the objection is