Reopening Assessments Beyond Four Years Requires AO to Prove Non-Disclosure of Material Facts by Assessee: ITAT

ITAT ruled that reopening assessments beyond four years requires the assessing officer to conclusively prove the assessee's failure to disclose material facts. Mere change of opinion or new interpretation doesn't justify belated reassessment. The decision places a heavy evidentiary burden on authorities in long-pending cases, protecting taxpayers from fishing expeditions. It clarifies that reassessment after four years is exceptional, not routine.