Pachamuthu Ravi v. DCIT (2025) 236 TTJ 961 (Chennai)(Trib)

S.147: Reassessment]-After the expiry of four years-No failure to disclose material facts-The essential conditions precedent to invoke the jurisdiction to reopen the assessment are absent-Consequently, issuance of notice under s. 148 is ab initio void.[S. 143(3), 148]

Tribunal held that the reasons recorded, the AO has not made a mention of assessee’s failure to disclose fully and truly material facts necessary for assessment; reopening is bad in law also for the reason that there is no indication that the AO received any fresh information/tangible material from external sources which formed the foundation for forming his belief that income chargeable to tax has escaped assessment(AY. 2014-15)

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