Tax Reassessment Upheld: Incomplete Disclosure Triggers Legitimate Reopening of Income Assessment Under Section 143(3)

HC ruled that the reassessment proceedings under Section 143(3) were valid despite time limitations. The AO had legitimate reasons to believe income had escaped assessment due to the petitioner's failure to fully disclose material facts regarding MAT exemption. Specifically, the petitioner claimed deductions from a BIFR scheme without proper CBDT authorization, which constituted non-disclosure. The court found the objection regarding time-barred notice involved complex factual and legal issues inappropriate for writ jurisdiction. Consequently, the writ petition was dismissed, upholding the AO's decision to reopen the assessment based on non-disclosure of essential tax-related information. .....

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