Reassessment reopening fails without an allegation of full and true disclosure failure in the recorded reasons.

Reassessment reopening is invalid where the recorded reasons do not allege that the assessee failed to disclose fully and truly all material facts necessary for assessment. The ITAT Delhi found that the reopening reasons contained no such allegation and therefore lacked the jurisdictional foundation required to invoke reassessment. Once that defect was established, the merits of the addition became academic. The reopening was quashed and the reassessment challenge succeeded.

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Issues: Whether the reassessment reopening was valid when the recorded reasons did not allege that the assessee had failed to disclose fully and truly all material facts necessary for assessment.

Analysis: The reopening reasons were examined and found to contain no allegation that the assessee had withheld or inadequately disclosed material particulars in the original assessment proceedings. In the absence of such an allegation in the recorded reasons, the jurisdictional basis for reopening was held to be defective. The remaining grounds on merits became academic once the reopening itself was invalidated.

Conclusion: The reopening was quashed and the challenge to reassessment succeeded.

Ratio Decidendi: A reassessment reopening is invalid where the recorded reasons fail to allege that the assessee did not disclose fully and truly all material facts necessary for assessment.

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