2021 (12) TMI 58 - BOMBAY HIGH COURT - Income Tax

Head Note / Extract:
Validity of Reopening of assessment u/s 147 - eligibility of reasons to believe - Notice after expiry of 4 years from the relevant Assessment Year - HELD THAT:- There is not even a whisper that there was failure on the part of the assessee to disclose fully and truly all material facts necessary for the assessment of that year. Failure to disclose would render the notice issued under Section 148 being held as without jurisdiction.