https://www.taxtmi.com/caselaws?id=331939 Reassessment initiated beyond four years was invalid because the original scrutiny assessment under section 143(3) had already examined the loan write-back and treated it as business income. The reopening reasons wrongly assumed escapement and alleged failure to disclose material facts, even though rectification proceedings on the same issue had earlier been initiated and then dropped. On these facts, the attempt to reopen amounted to a change of opinion, and the statutory condition of failure to disclose fully and truly all material facts was not met. The reassessment notice and the consequent assessment were therefore quashed. en-us Fri, 29 Jul 2016 00:00:00 +0530 Tue, 06 Sep 2016 13:22:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=331939 Reassessment initiated beyond four years was invalid because the original scrutiny assessment under section 143(3) had already examined the loan write-back and treated it as business income. The reopening reasons wrongly assumed escapement and alleged failure to disclose material facts, even though rectification proceedings on the same issue had earlier been initiated and then dropped. On these facts, the attempt to reopen amounted to a change of opinion, and the statutory condition of failure to disclose fully and truly all material facts was not met. The reassessment notice and the consequent assessment were therefore quashed. Case-Laws Income Tax Fri, 29 Jul 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=331939