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Reopening a completed scrutiny assessment beyond four years requires escapement of income to be attributable to the assessee's failure to disclose fully and truly all material facts. Where the immovable-property sale, sale consideration and explanation for the additional stamp-duty value were examined and disclosed in the original assessment, the recorded reasons must identify a material fact withheld by the assessee. A later different view on the same material, including the applicability of the stamp-duty valuation provision, amounts to a change of opinion and cannot meet the jurisdictional condition. The reassessment notice and consequential proceedings were therefore quashed.
Reopening a completed scrutiny assessment beyond four years requires escapement of income to be attributable to the assessee's failure to disclose fully and truly all material facts. Where the immovable-property sale, sale consideration and explanation for the additional stamp-duty value were examined and disclosed in the original assessment, the recorded reasons must identify a material fact withheld by the assessee. A later different view on the same material, including the applicability of the stamp-duty valuation provision, amounts to a change of opinion and cannot meet the jurisdictional condition. The reassessment notice and consequential proceedings were therefore quashed.
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