Absence of reasons to show failure of assessee to disclose facts won’t make re-assessment notice inv

IT : Where Assessing Officer initiated reassessment proceedings taking a view that deduction under section 80HHC was not available to assessee since it did not have profit from exports, since there was no failure on part of assessee to disclose truly and fully all material facts necessary for assessment, in view of proviso to section 147, initiation of reassessment proceedings after expiry of four years from end of relevant assessment year was not sustainable