Returns of income and subsequent correspondences make a full disclosure in the case of both assessees, and assessments have been framed after discussion and exchange of correspondence; having allowed matters to rest for so long, and in the light of the full and true disclosure made at the original instance, the impugned proceedings initiated beyond the period of four years, are barred by limitation and are quashed.Relied on Calcutta Discount Co. Ltd. v ITO (1961) 41 ITR 191 (SC) (AY. 2012-13) (SJ)
Ramesh Kymal v. Dy.CIT( IT)(2023) 334 CTR 533/227 DTR 85 (Mad) ( HC) Mangal Chand Ostwal v. ITO)(2023) 334 CTR 533/ 227 DTR 85 (Mad) ( HC)
S.147: Reassessment-After the expiry of four years-Long term capital gains-Sale of shares-Information from Investigation Wing-No failure to disclose material facts-Reassessment notice and order disposing the objection is quashed. [S.45, 148, Art. 226]