https://www.taxtmi.com/caselaws?id=441847 After four years from the end of the relevant assessment year, reassessment under Section 147 is permissible only where the recorded reasons specifically allege that the assessee failed to fully and truly disclose all material facts necessary for assessment. If the reasons contain no such allegation, and the material was already disclosed in the original scrutiny, reopening is invalid. A reassessment also cannot rest on an audit objection or a later change in treatment of the same item, because the Assessing Officer must form an independent belief based on his own reasons to believe. An audit-driven reopening in such circumstances amounts to a change of opinion and is legally unsustainable. en-us Tue, 08 Aug 2023 00:00:00 +0530 Wed, 11 Feb 2026 12:37:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=441847 After four years from the end of the relevant assessment year, reassessment under Section 147 is permissible only where the recorded reasons specifically allege that the assessee failed to fully and truly disclose all material facts necessary for assessment. If the reasons contain no such allegation, and the material was already disclosed in the original scrutiny, reopening is invalid. A reassessment also cannot rest on an audit objection or a later change in treatment of the same item, because the Assessing Officer must form an independent belief based on his own reasons to believe. An audit-driven reopening in such circumstances amounts to a change of opinion and is legally unsustainable. Case-Laws Income Tax Tue, 08 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=441847