https://www.taxtmi.com/caselaws?id=281993 Reassessment initiated beyond four years under section 147 was unsustainable because it relied on the same material used in the original scrutiny assessment and disclosed no fresh tangible material. The recorded reasons also failed to allege that the assessee had not fully and truly disclosed all material facts necessary for assessment, as required by the first proviso to section 147. On those facts, the reopening amounted to a mere change of opinion and could not be sustained. The reassessment proceedings under sections 147 and 148 were therefore invalid and quashed in favour of the assessee. en-us Mon, 26 Nov 2018 00:00:00 +0530 Wed, 17 Jul 2019 07:48:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=281993 Reassessment initiated beyond four years under section 147 was unsustainable because it relied on the same material used in the original scrutiny assessment and disclosed no fresh tangible material. The recorded reasons also failed to allege that the assessee had not fully and truly disclosed all material facts necessary for assessment, as required by the first proviso to section 147. On those facts, the reopening amounted to a mere change of opinion and could not be sustained. The reassessment proceedings under sections 147 and 148 were therefore invalid and quashed in favour of the assessee. Case-Laws Income Tax Mon, 26 Nov 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=281993