https://www.taxtmi.com/article/detailed?id=11276 Reopening an assessment beyond the statutory four year period cannot be based on a mere change of opinion. The Assessing Officer must have a recorded reason to believe that income escaped assessment and must establish that the assessee failed to disclose material facts fully and truly; the reasons recorded must identify tangible, undisclosed material and cannot be supplemented later. A notice issued without such tangible material or proof of nondisclosure is invalid and may be set aside. en-us Mon, 03 Apr 2023 12:43:04 +0530 Mon, 03 Apr 2023 12:43:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/article/detailed?id=11276 Reopening an assessment beyond the statutory four year period cannot be based on a mere change of opinion. The Assessing Officer must have a recorded reason to believe that income escaped assessment and must establish that the assessee failed to disclose material facts fully and truly; the reasons recorded must identify tangible, undisclosed material and cannot be supplemented later. A notice issued without such tangible material or proof of nondisclosure is invalid and may be set aside. Articles Income Tax Mon, 03 Apr 2023 12:43:04 +0530 https://www.taxtmi.com/article/detailed?id=11276