Investigation Wing Report Alone Insufficient to Sustain Section 147 Proceedings; Reassessment Beyond Four Years quashed; Deleted ₹5 Lakh Section 68 Addition: ITAT Mumbai
The Tribunal noted that where an assessment completed under Section 143(3) is sought to be reopened beyond four years, the Assessing Officer must record a specific finding that the assessee failed to disclose fully and truly all material facts.