This document explores the concept of 'True and Full Disclosure' in tax assessments and how it acts as a fetter on the Assessing Officer's (AO) power to reopen concluded cases. It delves into the legal provisions, case law, and the essential conditions that must be met by an assessee for a valid disclosure. This guide is particularly useful for tax professionals, legal practitioners, and assessees seeking to understand the limitations on AO's reassessment powers.
Article on the discussion regarding Proviso to S. 147 of the Income Tax Act including reference to the recent judgment of NDTV vs. DCIT [2020] 116 taxmann.com 151 (SC). #pdf