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The HC quashed reassessment initiated beyond four years from the end of the assessment year because it was based only on material already on record and showed no new tangible material. As the original assessment had been completed under Section 143(3), the first proviso to Section 147 required the Revenue to show that escaped income arose from the assessee's failure to disclose fully and truly all material facts. The recorded reasons contained only a bald assertion and did not identify any such failure. Reopening on the same material after the claim had already been examined was an impermissible change of opinion, so the notice under Section 148, the orders rejecting objections, and all consequential proceedings were set aside.
The HC quashed reassessment initiated beyond four years from the end of the assessment year because it was based only on material already on record and showed no new tangible material. As the original assessment had been completed under Section 143(3), the first proviso to Section 147 required the Revenue to show that escaped income arose from the assessee's failure to disclose fully and truly all material facts. The recorded reasons contained only a bald assertion and did not identify any such failure. Reopening on the same material after the claim had already been examined was an impermissible change of opinion, so the notice under Section 148, the orders rejecting objections, and all consequential proceedings were set aside.
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