JUDGMENT

Rajiv Shakdher, J.

Prefatory Facts

1. This appeal concerns Assessment Year (AY) 2006-07.

2. The appellant/revenue seeks to assail the order dated 31.10.2018 passed by the Income Tax Appellate Tribunal [in short, "Tribunal"].

2.1. The Tribunal, via the impugned order, has reversed the decision dated 10.11.2014 delivered by the Commissioner of Income Tax (Appeals) [in short, "CIT(A)"].

3. The short issue which arose for consideration before the Tribunal, in the backdrop of the facts and circumstances arising in the instant case, was: whether assessment could be reopened under Section 147 of the Income Tax Act, 1961 [in short, "Act"], in the absence of an allegation that the respondent/assessee had failed to disclose, fully and truly, all material facts necessary for carrying out the assessment, given the fact that the reassessment was triggered after the expiry of four (4) years from the end of relevant AY, i.e., AY 2006-07.

4. The factual backdrop in which the instant appeal has arisen, is as follows:

4.1. The respondent/assessee had electronically filed its Return of Income (ROI) on 02.02.2007. In the ROI, the respondent/assessee declared an income amounting to Rs.54,14,