https://www.taxtmi.com/caselaws?id=417274 A reassessment notice issued beyond four years from the end of the assessment year was held unsustainable where the recorded reasons relied on material already examined in the original scrutiny assessment under Section 143(3) and disclosed only a change of opinion. The first proviso to Section 147 applied, so the Revenue had to show failure by the assessee to fully and truly disclose all material facts necessary for assessment. As the reasons did not disclose any such failure, reopening lacked jurisdiction and the order rejecting objections to reopening also failed. The notice and rejection order were quashed. en-us Thu, 13 Jan 2022 00:00:00 +0530 Mon, 21 Nov 2022 11:50:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=417274 A reassessment notice issued beyond four years from the end of the assessment year was held unsustainable where the recorded reasons relied on material already examined in the original scrutiny assessment under Section 143(3) and disclosed only a change of opinion. The first proviso to Section 147 applied, so the Revenue had to show failure by the assessee to fully and truly disclose all material facts necessary for assessment. As the reasons did not disclose any such failure, reopening lacked jurisdiction and the order rejecting objections to reopening also failed. The notice and rejection order were quashed. Case-Laws Income Tax Thu, 13 Jan 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=417274