https://www.taxtmi.com/caselaws?id=12282 Reopening under ss. 147/148 beyond four years was challenged on the ground of absence of "reason to believe" and lack of failure to disclose material facts. The HC held that valid reassessment requires recorded reasons showing a live link between tangible material and the belief of escapement, and, after four years, a further satisfaction that escapement occurred due to the assessee's omission to disclose fully and truly all primary facts. Here, the recorded reasons lacked specific transaction material, the AO admitted no independent enquiry, and the assessee had disclosed all primary facts; reopening was thus only a change of opinion and not sustainable in law. The notice and consequential reassessment proceedings were quashed and the appeals were dismissed. en-us Tue, 13 Aug 2002 00:00:00 +0530 Wed, 31 Dec 2025 15:33:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=12282 Reopening under ss. 147/148 beyond four years was challenged on the ground of absence of "reason to believe" and lack of failure to disclose material facts. The HC held that valid reassessment requires recorded reasons showing a live link between tangible material and the belief of escapement, and, after four years, a further satisfaction that escapement occurred due to the assessee's omission to disclose fully and truly all primary facts. Here, the recorded reasons lacked specific transaction material, the AO admitted no independent enquiry, and the assessee had disclosed all primary facts; reopening was thus only a change of opinion and not sustainable in law. The notice and consequential reassessment proceedings were quashed and the appeals were dismissed. Case-Laws Income Tax Tue, 13 Aug 2002 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=12282