https://www.taxtmi.com/caselaws?id=207152 Reassessment initiated beyond four years after a scrutiny assessment under Section 143(3) was considered invalid where the assessee had disclosed the relevant particulars and no failure of full and true disclosure was shown. Reopening based only on an internal audit objection and material already on record amounted to a change of opinion, which is insufficient for Section 147 action after the four-year period. A completed scrutiny assessment carries a presumption of due application of mind, and reassessment requires tangible material showing reason to believe that income has escaped assessment. On that reasoning, the text states that the reassessment proceedings under Sections 147 and 148 were invalid. en-us Wed, 09 Mar 2011 00:00:00 +0530 Mon, 26 Mar 2012 15:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=207152 Reassessment initiated beyond four years after a scrutiny assessment under Section 143(3) was considered invalid where the assessee had disclosed the relevant particulars and no failure of full and true disclosure was shown. Reopening based only on an internal audit objection and material already on record amounted to a change of opinion, which is insufficient for Section 147 action after the four-year period. A completed scrutiny assessment carries a presumption of due application of mind, and reassessment requires tangible material showing reason to believe that income has escaped assessment. On that reasoning, the text states that the reassessment proceedings under Sections 147 and 148 were invalid. Case-Laws Income Tax Wed, 09 Mar 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=207152