https://www.taxtmi.com/caselaws?id=31803 HC held that the notice under section 148 and consequent order were without jurisdiction and quashed the notice dated 28.03.2008 and set aside the order dated 28.11.2008. The court found that mere belief of escaped income was insufficient to reopen assessments beyond four years; reopening after four years requires an allegation that the assessee failed to disclose material facts fully and truly. Because the recorded reasons did not allege such nondisclosure, the proviso to section 147 was not satisfied and action under section 147 could not be taken. en-us Wed, 10 Dec 2008 00:00:00 +0530 Fri, 07 Nov 2025 16:33:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=31803 HC held that the notice under section 148 and consequent order were without jurisdiction and quashed the notice dated 28.03.2008 and set aside the order dated 28.11.2008. The court found that mere belief of escaped income was insufficient to reopen assessments beyond four years; reopening after four years requires an allegation that the assessee failed to disclose material facts fully and truly. Because the recorded reasons did not allege such nondisclosure, the proviso to section 147 was not satisfied and action under section 147 could not be taken. Case-Laws Income Tax Wed, 10 Dec 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=31803