https://www.taxtmi.com/caselaws?id=390443 Reassessment notices issued beyond four years after scrutiny assessments under Section 143(3) were invalid because the recorded reasons did not show any failure by the assessee to fully and truly disclose material facts. The Assessing Officer had already examined the EDC payments and TDS particulars during the original proceedings, and no fresh tangible material or live link to escapement of income was identified. The reasons also failed to explain how the payments attracted TDS under the cited provisions, reflecting non-application of mind and a mere change of opinion. The notices and consequential proceedings were therefore unsustainable. en-us Thu, 28 Nov 2019 00:00:00 +0530 Wed, 19 Feb 2020 15:17:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=390443 Reassessment notices issued beyond four years after scrutiny assessments under Section 143(3) were invalid because the recorded reasons did not show any failure by the assessee to fully and truly disclose material facts. The Assessing Officer had already examined the EDC payments and TDS particulars during the original proceedings, and no fresh tangible material or live link to escapement of income was identified. The reasons also failed to explain how the payments attracted TDS under the cited provisions, reflecting non-application of mind and a mere change of opinion. The notices and consequential proceedings were therefore unsustainable. Case-Laws Income Tax Thu, 28 Nov 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=390443