https://www.taxtmi.com/caselaws?id=217635 Reassessment beyond four years is invalid unless escapement of income is attributable to the assessee's failure to disclose fully and truly all material facts. Here, the assessee had placed the relevant computation details, including carried-forward losses and income figures, before the Assessing Officer, and the reopening materials did not show any independent basis for alleging suppression. In the absence of tangible material establishing such failure, the jurisdictional condition under the proviso to Section 147 was not met. The HC also applied the rule that reassessment cannot proceed on a mere change of opinion. The reopening was therefore barred by limitation and set aside in favour of the assessee. en-us Mon, 01 Oct 2012 00:00:00 +0530 Sat, 20 Oct 2012 09:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=217635 Reassessment beyond four years is invalid unless escapement of income is attributable to the assessee's failure to disclose fully and truly all material facts. Here, the assessee had placed the relevant computation details, including carried-forward losses and income figures, before the Assessing Officer, and the reopening materials did not show any independent basis for alleging suppression. In the absence of tangible material establishing such failure, the jurisdictional condition under the proviso to Section 147 was not met. The HC also applied the rule that reassessment cannot proceed on a mere change of opinion. The reopening was therefore barred by limitation and set aside in favour of the assessee. Case-Laws Income Tax Mon, 01 Oct 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=217635