Bombay High Court: Reassessment Beyond 4 Years Under IT Act Requires Specific Allegation of Non-Disclosure

The Bombay High Court has held that reassessment under Section 147 of the Income Tax Act, 1961, beyond four years from the relevant assessment year is not valid unless there is a specific allegation that the assessee failed to fully and truly disclose material facts.

The Court clarified that vague or general statements by the Assessing Officer are insufficient to reopen assessments after the four-year window.

The court held that in the absence of any clear failure on the part of the assessee to fully and truly disclose material facts, the reassessment is not valid in law.