https://www.taxtmi.com/caselaws?id=373379 Reassessment beyond four years under the Income-tax Act requires a failure by the assessee to disclose fully and truly all material facts; the note states that, where the recorded reasons do not identify any withheld fact and instead rely on a later view on eligibility, the reopening is invalid. It also states that once the original scrutiny assessment has examined the relevant claim and the Assessing Officer has considered the material before accepting the return, reopening without fresh tangible material amounts to a change of opinion, which is impermissible. On that reasoning, the notice for reopening was quashed and the Revenue's challenge failed. en-us Thu, 03 Jan 2019 00:00:00 +0530 Fri, 11 Jan 2019 11:45:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=373379 Reassessment beyond four years under the Income-tax Act requires a failure by the assessee to disclose fully and truly all material facts; the note states that, where the recorded reasons do not identify any withheld fact and instead rely on a later view on eligibility, the reopening is invalid. It also states that once the original scrutiny assessment has examined the relevant claim and the Assessing Officer has considered the material before accepting the return, reopening without fresh tangible material amounts to a change of opinion, which is impermissible. On that reasoning, the notice for reopening was quashed and the Revenue's challenge failed. Case-Laws Income Tax Thu, 03 Jan 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=373379