https://www.taxtmi.com/caselaws?id=389156 Reassessment initiated after four years from the end of the assessment year requires a recorded failure by the assessee to fully and truly disclose all material facts; absent that jurisdictional , reopening cannot stand. Here, the recorded reasons relied only on the assessee's own financial statements and the treatment of shareholders' accounts, without alleging non-disclosure or citing new tangible material. As the same issue had already been examined in the original assessment on a detailed explanation from the assessee, the reopening was treated as a mere change of opinion and stated to be invalid, with the notice and consequential reassessment liable to be quashed. en-us Tue, 19 Nov 2019 00:00:00 +0530 Mon, 02 Dec 2019 16:57:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=389156 Reassessment initiated after four years from the end of the assessment year requires a recorded failure by the assessee to fully and truly disclose all material facts; absent that jurisdictional , reopening cannot stand. Here, the recorded reasons relied only on the assessee's own financial statements and the treatment of shareholders' accounts, without alleging non-disclosure or citing new tangible material. As the same issue had already been examined in the original assessment on a detailed explanation from the assessee, the reopening was treated as a mere change of opinion and stated to be invalid, with the notice and consequential reassessment liable to be quashed. Case-Laws Income Tax Tue, 19 Nov 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=389156