Allowing the petition the Court held that there was no allegation that assessee failed to disclose fully and truly all material facts necessary for his assessment. Neither notice, nor reasons disclosed what was suppressed by assessee and how such suppression offered Assessing Officer reason to believe that income had escaped assessment. Reassessment notice and order disposing the objection is quashed. (AY. 2015-16)
Teofilo Fernando Antonio Pinto v. UOI (2023) 295 Taxman 633 (Bom.)(HC)
S. 147 : Reassessment-After the expiry of four years-Capital gains-Cost of acquisition-No failure to disclose material facts-Reassessment notice and order disposing the objection is quashed. [S. 45, 48, 148, Art. 226]