Reopening Beyond 4 Years Invalid if Material Facts Disclosed: Madras HC Dismisses Revenue's Appeal

The Madras High Court has dismissed the Revenue's appeal, ruling that "reopening beyond 4 years is invalid if material facts disclosed." The court reaffirmed that under Section 147 of the Income Tax Act, an assessment cannot be reopened after four years from the end of the relevant assessment year if the assessee had fully and truly disclosed all material facts during the original assessment. This decision protects compliant taxpayers from arbitrary reassessment proceedings based on a mere change of opinion by the tax authorities.