https://www.taxtmi.com/caselaws?id=418788 Reassessment beyond four years under the proviso to Section 147 was invalid because the recorded reasons did not allege any failure by the assessee to fully and truly disclose material facts after an assessment under Section 143(3). The material relied on for reopening had already been placed in the return, tax audit report, audited accounts and computations, and was considered in the original assessment. Reopening on the same material amounted to a mere change of opinion and could not support a valid belief that income had escaped assessment. The reassessment was therefore struck down in favour of the assessee. en-us Fri, 18 Feb 2022 00:00:00 +0530 Mon, 16 Jan 2023 17:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=418788 Reassessment beyond four years under the proviso to Section 147 was invalid because the recorded reasons did not allege any failure by the assessee to fully and truly disclose material facts after an assessment under Section 143(3). The material relied on for reopening had already been placed in the return, tax audit report, audited accounts and computations, and was considered in the original assessment. Reopening on the same material amounted to a mere change of opinion and could not support a valid belief that income had escaped assessment. The reassessment was therefore struck down in favour of the assessee. Case-Laws Income Tax Fri, 18 Feb 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=418788