AdvertisementParas Polycab Pvt. Ltd. Vs ITO (ITAT Delhi) Delhi ITAT Quashes Reassessment of ₹1.88 Crore Bogus Purchases: Reopening Beyond 4 Years Invalid When Purchases Were Fully Examined in Original Scrutiny The Delhi ITAT quashed reassessment proceedings initiated under section 147, holding that where the assessee had fully disclosed the relevant purchase transactions and the AO had specifically examined them during the original scrutiny assessment, the same matter could not be reopened beyond four years without establishing failure by the assessee to disclose fully and truly all material facts.