No reassessment beyond four years due to TDS default if assessee had disclosed all facts during asse

IT: Where assessee disclosed all material facts necessary for completing assessment, in view of proviso to section 147, Assessing Officer could not initiate reassessment proceedings after expiry of four years from end of relevant assessment year on ground that assessee had made payments of salary to its employees rendering services abroad without deducting tax at source and, thus, amount so paid was liable to be disallowed under section 40(a)(iii)