https://www.taxtmi.com/caselaws?id=386605 Reopening of assessment beyond four years under section 147 was invalid because the recorded reasons relied on material already available in the original return, tax audit report and assessment records. In the absence of any allegation or material showing failure to disclose fully and truly all material facts, the first proviso to section 147 barred reassessment. The court held that reopening on the same material amounted to a change of opinion, and the mere absence of discussion in the original assessment order did not justify an inference that the issue had not been examined. The reopening was quashed as time-barred. en-us Thu, 26 Sep 2019 00:00:00 +0530 Tue, 03 Dec 2019 15:12:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=386605 Reopening of assessment beyond four years under section 147 was invalid because the recorded reasons relied on material already available in the original return, tax audit report and assessment records. In the absence of any allegation or material showing failure to disclose fully and truly all material facts, the first proviso to section 147 barred reassessment. The court held that reopening on the same material amounted to a change of opinion, and the mere absence of discussion in the original assessment order did not justify an inference that the issue had not been examined. The reopening was quashed as time-barred. Case-Laws Income Tax Thu, 26 Sep 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=386605