https://www.taxtmi.com/caselaws?id=193169 Reassessment initiated after four years was invalid where the original scrutiny assessment under section 143(3) had already examined the bank deposits, considered the assessee's explanation and supporting records, and made no addition. On the same material, reopening amounted to a change of opinion. As the first proviso to section 147 required a failure to disclose fully and truly all material facts, and no such failure was shown, the reassessment was without jurisdiction and unsustainable in favour of the assessee. en-us Wed, 17 Feb 2016 00:00:00 +0530 Sat, 15 Jul 2017 15:28:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=193169 Reassessment initiated after four years was invalid where the original scrutiny assessment under section 143(3) had already examined the bank deposits, considered the assessee's explanation and supporting records, and made no addition. On the same material, reopening amounted to a change of opinion. As the first proviso to section 147 required a failure to disclose fully and truly all material facts, and no such failure was shown, the reassessment was without jurisdiction and unsustainable in favour of the assessee. Case-Laws Income Tax Wed, 17 Feb 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=193169