Concluded assessment was sought to be reopened after four years on the basis of assessment of subsequent years. It was held by the Tribunal that thought in the reasons recorded, it was held that the assessee had failed to disclose fully and truly all material facts, no reference was made in the reasons to the material facts not so disclosed. Accordingly, the reassessment was held to be bad in law. ( AY.2006-07)
Dy. CIT v. Wind World (India) Limited (2018) 63 ITR 599 (Mum.)(Trib.)
S.147: Reassessment-After the expiry of four years- Concluded assessment reopened after four years on the basis of assessment of subsequent years – Held, no failure on the part of the assessee to disclose fully and truly all material facts – Held, reassessment not valid.