Dismissing the appeal of the revenue the Court held that ; there was no averment of failure on part of assessee to disclose fully and truly all material facts necessary for assessment . Merely on the basis of information from investigation wing ,reassessment was held to be not valid (ITA No. 117 of 2016 dt. 23 -8-2017 )(AY.2005 -06)
PCIT v. Light Carts P. Ltd ( 2018) 404 ITR 574 ( All) (HC)
S.147: Reassessment-After the expiry of four years- Information from investigation wing -No averment of failure on part of the assessee to disclose fully and truly all material facts necessary for assessment – Reassessment is held to be not valid [ S.148 ]