https://www.taxtmi.com/caselaws?id=439715 Reassessment notices issued beyond four years are invalid unless the recorded reasons show a live nexus between tangible material and a failure by the assessee to fully and truly disclose material facts necessary for assessment. Where the assessee had already disclosed trading transactions, profit and loss details, and supporting documents in a scrutiny assessment, reopening could not be justified on the basis of unparticularised investigation or SEBI-related information. In the absence of specific material showing what primary fact was withheld or how escapement of income was established, the reopening amounted to a mere change of opinion. The challenge to the reassessment reopening therefore succeeded in favour of the assessee. en-us Tue, 27 Jun 2023 00:00:00 +0530 Fri, 01 Mar 2024 12:03:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=439715 Reassessment notices issued beyond four years are invalid unless the recorded reasons show a live nexus between tangible material and a failure by the assessee to fully and truly disclose material facts necessary for assessment. Where the assessee had already disclosed trading transactions, profit and loss details, and supporting documents in a scrutiny assessment, reopening could not be justified on the basis of unparticularised investigation or SEBI-related information. In the absence of specific material showing what primary fact was withheld or how escapement of income was established, the reopening amounted to a mere change of opinion. The challenge to the reassessment reopening therefore succeeded in favour of the assessee. Case-Laws Income Tax Tue, 27 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=439715