https://www.taxtmi.com/caselaws?id=15661 Reassessment notice issued beyond four years from the end of the assessment year is valid only if the recorded reasons show that income escaped assessment because the assessee failed to disclose fully and truly all material facts. Mere escapement of income is not enough. On the facts discussed, the assessee had disclosed the relevant deduction claims, excise duty payments, Modvat adjustment, and supporting working statements, so any mistake arose from the Assessing Officer's understanding rather than from nondisclosure by the assessee. The recorded reasons therefore did not satisfy the jurisdictional condition for reopening, and the notice under section 148 was treated as without jurisdiction. en-us Fri, 27 Nov 1998 00:00:00 +0530 Fri, 12 Dec 2025 16:14:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=15661 Reassessment notice issued beyond four years from the end of the assessment year is valid only if the recorded reasons show that income escaped assessment because the assessee failed to disclose fully and truly all material facts. Mere escapement of income is not enough. On the facts discussed, the assessee had disclosed the relevant deduction claims, excise duty payments, Modvat adjustment, and supporting working statements, so any mistake arose from the Assessing Officer's understanding rather than from nondisclosure by the assessee. The recorded reasons therefore did not satisfy the jurisdictional condition for reopening, and the notice under section 148 was treated as without jurisdiction. Case-Laws Income Tax Fri, 27 Nov 1998 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=15661