https://www.taxtmi.com/caselaws?id=326520 A reassessment notice issued beyond four years from the end of the relevant assessment year is invalid unless the revenue also shows failure by the assessee to make a return or to disclose fully and truly all material facts necessary for assessment. Where the original assessment was completed under section 143(3) and there is no such allegation or supporting material, reopening cannot be sustained. Reappraisal of the same material already before the Assessing Officer amounts only to a change of opinion, which does not confer jurisdiction under sections 147 and 148. The reassessment was therefore quashed as beyond jurisdiction. en-us Fri, 04 Mar 2016 00:00:00 +0530 Mon, 18 Apr 2016 08:14:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=326520 A reassessment notice issued beyond four years from the end of the relevant assessment year is invalid unless the revenue also shows failure by the assessee to make a return or to disclose fully and truly all material facts necessary for assessment. Where the original assessment was completed under section 143(3) and there is no such allegation or supporting material, reopening cannot be sustained. Reappraisal of the same material already before the Assessing Officer amounts only to a change of opinion, which does not confer jurisdiction under sections 147 and 148. The reassessment was therefore quashed as beyond jurisdiction. Case-Laws Income Tax Fri, 04 Mar 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=326520