Shanti Prime Publication Pvt. Ltd.
Sec. 147 of Income Tax Act, 1961 – Reassessment - The petitioner challenged the notice issued under section 148 of the IT Act, 1961 seeking to reopen the assessment of the petitioner for assessment year 2008-2009 as well as the orders whereby the respondent rejected the objections raised by the petitioner to the reopening of assessment. Writ application of the petition came to be allowed holding that ”in the absence of any failure on the part of the petitioner to disclose fully and truly all material facts necessary for his assessment, the reopening of assessment beyond a period of four years from the relevant assessment is without authority of law“. Thus, impugned notice as well as all proceedings pursuant thereto quashed and set aside.
Jayesh t kotak Vs. Dy. CIT
 424 ITR 435 (GUJ)