https://www.taxtmi.com/caselaws?id=391210 Reopening of a completed assessment under section 147/148 after four years was not sustainable where the original section 143(3) assessment had already examined the TDS issue and the recorded reasons relied on the same material in the record. The reassessment notice also did not allege that the assessee had failed to disclose fully and truly all material facts necessary for assessment, which is a jurisdictional requirement under the first proviso to section 147. On these facts, the reopening amounted only to a review or change of opinion, so the reassessment proceedings were without jurisdiction. en-us Mon, 20 Jan 2020 00:00:00 +0530 Wed, 22 Jan 2020 10:19:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=391210 Reopening of a completed assessment under section 147/148 after four years was not sustainable where the original section 143(3) assessment had already examined the TDS issue and the recorded reasons relied on the same material in the record. The reassessment notice also did not allege that the assessee had failed to disclose fully and truly all material facts necessary for assessment, which is a jurisdictional requirement under the first proviso to section 147. On these facts, the reopening amounted only to a review or change of opinion, so the reassessment proceedings were without jurisdiction. Case-Laws Income Tax Mon, 20 Jan 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=391210