https://www.taxtmi.com/caselaws?id=432326 Reopening of assessment beyond four years under section 148 requires recorded reasons to show failure to fully and truly disclose material facts. Where that jurisdictional fact is absent, and the notice is based only on a change of opinion, the reopening cannot be sustained. The recorded reasons in this instance did not disclose the required non-disclosure by the assessee, so the notice was invalid and the High Court's quashing of it was upheld. en-us Mon, 10 Oct 2022 00:00:00 +0530 Tue, 03 Jan 2023 08:23:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=432326 Reopening of assessment beyond four years under section 148 requires recorded reasons to show failure to fully and truly disclose material facts. Where that jurisdictional fact is absent, and the notice is based only on a change of opinion, the reopening cannot be sustained. The recorded reasons in this instance did not disclose the required non-disclosure by the assessee, so the notice was invalid and the High Court's quashing of it was upheld. Case-Laws Income Tax Mon, 10 Oct 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=432326