https://www.taxtmi.com/caselaws?id=268329 Reassessment beyond four years is invalid unless the recorded reasons expressly show that the assessee failed to fully and truly disclose all material facts necessary for assessment; that statutory precondition was absent, so the reopening could not stand. Reopening was also impermissible because the same agreements and materials had already been examined in the original assessment, making the exercise a mere change of opinion. The notice under section 148 and all consequential proceedings were quashed. en-us Thu, 19 Nov 2015 00:00:00 +0530 Mon, 23 Nov 2015 21:10:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=268329 Reassessment beyond four years is invalid unless the recorded reasons expressly show that the assessee failed to fully and truly disclose all material facts necessary for assessment; that statutory precondition was absent, so the reopening could not stand. Reopening was also impermissible because the same agreements and materials had already been examined in the original assessment, making the exercise a mere change of opinion. The notice under section 148 and all consequential proceedings were quashed. Case-Laws Income Tax Thu, 19 Nov 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=268329