https://www.taxtmi.com/caselaws?id=442306 Reassessment beyond four years under Section 147 is valid only where the assessee failed to fully and truly disclose material facts. Here, the deduction claim and supporting form had already been queried in the original assessment, and the assessee had provided explanations and approvals, so the issue was treated as examined even though the assessment order was silent. The recorded reasons therefore reflected a mere change of opinion, which cannot justify reopening. The reopening was also weakened because it relied on revenue audit objections rather than an independently formed belief by the Assessing Officer. The Section 148 notice and the order rejecting objections were quashed. en-us Fri, 18 Aug 2023 00:00:00 +0530 Mon, 28 Aug 2023 22:14:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=442306 Reassessment beyond four years under Section 147 is valid only where the assessee failed to fully and truly disclose material facts. Here, the deduction claim and supporting form had already been queried in the original assessment, and the assessee had provided explanations and approvals, so the issue was treated as examined even though the assessment order was silent. The recorded reasons therefore reflected a mere change of opinion, which cannot justify reopening. The reopening was also weakened because it relied on revenue audit objections rather than an independently formed belief by the Assessing Officer. The Section 148 notice and the order rejecting objections were quashed. Case-Laws Income Tax Fri, 18 Aug 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=442306