https://www.taxtmi.com/caselaws?id=15698 Reassessment beyond four years under the Income-tax Act is valid only if the statutory conditions for reopening are met, including the proviso to section 147 read with section 149. The assessee must disclose fully and truly all primary facts necessary for assessment; merely filing books or general material is not enough. Where the record did not show disclosure of primary facts relevant to the section 80-I claim, and later information supplied the basis for the Assessing Officer's belief that income had escaped assessment, the reopening was treated as founded on fresh material and not on a mere change of opinion. The reassessment notices were therefore upheld. en-us Fri, 23 Oct 1998 00:00:00 +0530 Wed, 17 Dec 2025 13:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=15698 Reassessment beyond four years under the Income-tax Act is valid only if the statutory conditions for reopening are met, including the proviso to section 147 read with section 149. The assessee must disclose fully and truly all primary facts necessary for assessment; merely filing books or general material is not enough. Where the record did not show disclosure of primary facts relevant to the section 80-I claim, and later information supplied the basis for the Assessing Officer's belief that income had escaped assessment, the reopening was treated as founded on fresh material and not on a mere change of opinion. The reassessment notices were therefore upheld. Case-Laws Income Tax Fri, 23 Oct 1998 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=15698