https://www.taxtmi.com/caselaws?id=219770 Second reassessment notices were invalid because they were founded on the same master licensing agreement and royalty receipts already examined in the original assessment and first reassessment. In proceedings beyond four years, reopening required a recorded failure by the assessee to disclose fully and truly all material facts necessary for assessment; no such failure was recorded. The court treated the reopening as a mere change of opinion based on reappraisal of already disclosed primary facts, and held that the Assessing Officer, not the assessee, was responsible for drawing the legal inference from those facts. The reassessment proceedings were therefore held to be without jurisdiction and the issue was decided in favour of the assessee. en-us Tue, 11 Dec 2012 00:00:00 +0530 Mon, 24 Dec 2012 15:01:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=219770 Second reassessment notices were invalid because they were founded on the same master licensing agreement and royalty receipts already examined in the original assessment and first reassessment. In proceedings beyond four years, reopening required a recorded failure by the assessee to disclose fully and truly all material facts necessary for assessment; no such failure was recorded. The court treated the reopening as a mere change of opinion based on reappraisal of already disclosed primary facts, and held that the Assessing Officer, not the assessee, was responsible for drawing the legal inference from those facts. The reassessment proceedings were therefore held to be without jurisdiction and the issue was decided in favour of the assessee. Case-Laws Income Tax Tue, 11 Dec 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=219770