https://www.taxtmi.com/caselaws?id=216278 Reassessment notice issued beyond four years from the end of the assessment year was invalid because the Revenue did not establish any failure by the assessee to fully and truly disclose all material facts necessary for assessment. The assessee's permanent establishment issue had already been examined in the earlier round, and no fresh or additional material supported the second reopening. On the recorded reasons, the reopening was therefore a mere change of opinion, and the jurisdictional requirement for invoking the proviso to Section 147 was not met. The notice was consequently barred by limitation and could not be sustained. en-us Wed, 29 Aug 2012 00:00:00 +0530 Tue, 04 Sep 2012 13:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=216278 Reassessment notice issued beyond four years from the end of the assessment year was invalid because the Revenue did not establish any failure by the assessee to fully and truly disclose all material facts necessary for assessment. The assessee's permanent establishment issue had already been examined in the earlier round, and no fresh or additional material supported the second reopening. On the recorded reasons, the reopening was therefore a mere change of opinion, and the jurisdictional requirement for invoking the proviso to Section 147 was not met. The notice was consequently barred by limitation and could not be sustained. Case-Laws Income Tax Wed, 29 Aug 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=216278