https://www.taxtmi.com/caselaws?id=412172 HC quashed the reassessment proceedings initiated under s.147 beyond four years, holding the notice invalid and unenforceable. The AO failed to demonstrate any fresh tangible material received after completion of the original scrutiny assessment; the relied-upon statement and data were already on record and considered earlier. The generalized reference to an investigation into penny stock transactions, without specific, new information linked to the assessee, did not constitute "reason to believe" that income had escaped assessment. As there was no failure by the assessee to fully and truly disclose material facts, the jurisdictional preconditions under the proviso to s.147 were not satisfied. The reassessment was therefore set aside in favour of the assessee. en-us Tue, 24 Aug 2021 00:00:00 +0530 Mon, 15 Dec 2025 16:23:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=412172 HC quashed the reassessment proceedings initiated under s.147 beyond four years, holding the notice invalid and unenforceable. The AO failed to demonstrate any fresh tangible material received after completion of the original scrutiny assessment; the relied-upon statement and data were already on record and considered earlier. The generalized reference to an investigation into penny stock transactions, without specific, new information linked to the assessee, did not constitute "reason to believe" that income had escaped assessment. As there was no failure by the assessee to fully and truly disclose material facts, the jurisdictional preconditions under the proviso to s.147 were not satisfied. The reassessment was therefore set aside in favour of the assessee. Case-Laws Income Tax Tue, 24 Aug 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=412172