https://www.taxtmi.com/caselaws?id=404181 Reassessment issued after four years from the end of the assessment year was held invalid where the original assessment had been completed under section 143(3) and the recorded reasons did not allege any failure to disclose fully and truly all material facts. The reopening was examined only on the recorded reasons, which incorrectly assumed an assessment under section 143(1) and were unsupported by fresh tangible material linking any material to a belief of escapement of income. On those facts, the notice under section 148 was treated as a mere change of opinion and without jurisdiction, so the reassessment proceedings were quashed and the addition could not survive. en-us Mon, 15 Feb 2021 00:00:00 +0530 Thu, 18 Feb 2021 04:22:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=404181 Reassessment issued after four years from the end of the assessment year was held invalid where the original assessment had been completed under section 143(3) and the recorded reasons did not allege any failure to disclose fully and truly all material facts. The reopening was examined only on the recorded reasons, which incorrectly assumed an assessment under section 143(1) and were unsupported by fresh tangible material linking any material to a belief of escapement of income. On those facts, the notice under section 148 was treated as a mere change of opinion and without jurisdiction, so the reassessment proceedings were quashed and the addition could not survive. Case-Laws Income Tax Mon, 15 Feb 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=404181