https://www.taxtmi.com/caselaws?id=417071 Reopening of assessment beyond four years under section 147 requires a jurisdictional showing that the assessee failed to fully and truly disclose all material facts. Where the notice under section 148 was based on the same sales and purchase statements already filed in the original section 143(3) proceedings, and the recorded reasons reflected only an arithmetical reworking of existing figures without fresh tangible material, the reassessment amounts to mere reappraisal of disclosed material. On those facts, the assumption of jurisdiction under section 147 was held invalid and the reassessment was not sustainable. en-us Tue, 11 Jan 2022 00:00:00 +0530 Fri, 14 Jan 2022 08:39:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=417071 Reopening of assessment beyond four years under section 147 requires a jurisdictional showing that the assessee failed to fully and truly disclose all material facts. Where the notice under section 148 was based on the same sales and purchase statements already filed in the original section 143(3) proceedings, and the recorded reasons reflected only an arithmetical reworking of existing figures without fresh tangible material, the reassessment amounts to mere reappraisal of disclosed material. On those facts, the assumption of jurisdiction under section 147 was held invalid and the reassessment was not sustainable. Case-Laws Income Tax Tue, 11 Jan 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=417071