https://www.taxtmi.com/caselaws?id=75513 The HC allowed the petition, holding the section 148 notice invalid. The court found the taxpayer had fully disclosed material facts in the return and accompanying schedules, so Explanation I to section 147 did not apply. The HC held reasons for reopening must be recorded by the Assessing Officer and cannot be supplemented or altered by a subsequent order to change the case's complexion. A notice issued after the four-year period, lacking proper recorded reasons and attempting to rely on supplemental explanations, was therefore unsustainable. en-us Mon, 20 Oct 2008 00:00:00 +0530 Mon, 10 Nov 2025 14:39:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=75513 The HC allowed the petition, holding the section 148 notice invalid. The court found the taxpayer had fully disclosed material facts in the return and accompanying schedules, so Explanation I to section 147 did not apply. The HC held reasons for reopening must be recorded by the Assessing Officer and cannot be supplemented or altered by a subsequent order to change the case's complexion. A notice issued after the four-year period, lacking proper recorded reasons and attempting to rely on supplemental explanations, was therefore unsustainable. Case-Laws Income Tax Mon, 20 Oct 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=75513