https://www.taxtmi.com/caselaws?id=427820 Reopening beyond four years after a completed scrutiny assessment under section 143(3) is valid only where the recorded reasons show a specific failure by the assessee to disclose fully and truly all material facts. Where the audited accounts and return records already disclosed the project expenses written off, and the reasons rely on the same material without fresh tangible evidence, the proviso to section 147 is not satisfied. A reassessment on that basis amounts to a mere change of opinion and cannot stand. The reopening was held invalid, the reassessment was quashed, and the addition challenge became academic. en-us Wed, 14 Sep 2022 00:00:00 +0530 Fri, 16 Sep 2022 12:16:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=427820 Reopening beyond four years after a completed scrutiny assessment under section 143(3) is valid only where the recorded reasons show a specific failure by the assessee to disclose fully and truly all material facts. Where the audited accounts and return records already disclosed the project expenses written off, and the reasons rely on the same material without fresh tangible evidence, the proviso to section 147 is not satisfied. A reassessment on that basis amounts to a mere change of opinion and cannot stand. The reopening was held invalid, the reassessment was quashed, and the addition challenge became academic. Case-Laws Income Tax Wed, 14 Sep 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=427820