[Income Tax Act] Reassessment Beyond 4 Years Requires Specific Non-Disclosure By Assessee, Not Mere Allegations: Bombay High Court

The Bombay High Court has ruled that reassessment under Section 147 of the Income Tax Act beyond 4 years requires specific non-disclosure by the assessee, not mere bald allegations. This crucial decision provides significant relief to taxpayers, limiting the arbitrary reopening of assessments. Section 147 allows reassessment if income has escaped. The court emphasized that beyond four years from the end of the relevant assessment year, the tax department must prove that the escapement of income was due to the assessee's failure to fully and truly disclose material facts. Mere change of opinion or general suspicion is insufficient, ensuring greater finality to assessments.