https://www.taxtmi.com/caselaws?id=420959 Reassessment initiated after four years from the end of the relevant assessment year was unsustainable where the original scrutiny assessment under section 143(3) had been completed and the record showed full disclosure of material facts by the assessee. In the absence of any averment or finding of failure to disclose fully and truly all facts necessary for assessment, the reopening was treated as a mere change of opinion and was barred by the proviso to section 147 of the Income-tax Act, 1961. The reassessment notice and consequential rejection order were quashed. en-us Tue, 05 Apr 2022 00:00:00 +0530 Mon, 10 Oct 2022 10:37:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=420959 Reassessment initiated after four years from the end of the relevant assessment year was unsustainable where the original scrutiny assessment under section 143(3) had been completed and the record showed full disclosure of material facts by the assessee. In the absence of any averment or finding of failure to disclose fully and truly all facts necessary for assessment, the reopening was treated as a mere change of opinion and was barred by the proviso to section 147 of the Income-tax Act, 1961. The reassessment notice and consequential rejection order were quashed. Case-Laws Income Tax Tue, 05 Apr 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=420959