https://www.taxtmi.com/caselaws?id=151528 Reassessment under section 147 after four years from the end of the relevant assessment year requires a showing that the assessee failed to disclose fully and truly all material facts necessary for assessment. Where the original assessment was completed under section 143(3) and reopening is based on the same material already on record, a mere change of view on disclosed facts does not satisfy the proviso to section 147. On those facts, the reopening was treated as invalid for want of jurisdiction and the reassessment was quashed. en-us Wed, 16 Dec 2009 00:00:00 +0530 Thu, 06 Jun 2013 18:31:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=151528 Reassessment under section 147 after four years from the end of the relevant assessment year requires a showing that the assessee failed to disclose fully and truly all material facts necessary for assessment. Where the original assessment was completed under section 143(3) and reopening is based on the same material already on record, a mere change of view on disclosed facts does not satisfy the proviso to section 147. On those facts, the reopening was treated as invalid for want of jurisdiction and the reassessment was quashed. Case-Laws Income Tax Wed, 16 Dec 2009 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=151528