Dismissing the appeal, that it could not be said that there was any suppression on the part of the assessee in disclosing true and correct facts. The reassessment proceedings were initiated beyond the period of four years. Under the circumstances, the High Court was absolutely justified in quashing the reassessment proceedings and the notice under section 148 of the Act. (AY. 2012-13)
ITO v. Kayathwal Estate P. Ltd. (2022) 442 ITR 507 / 213 DTR 209 / 326 CTR 494 / 287 Taxman 385 (SC) Editorial : Decision in Kayathwal Estate P. Ltd v. ITO (2022) 442 ITR 498 (Guj.)(HC) is affirmed.
S. 147 : Reassessment-After the expiry of four years-Order passed after pursuing details furnished-Reassessment notice is not valid. [S. 143(3), 148]