https://www.taxtmi.com/caselaws?id=35247 Reassessment under sections 147/148 was treated as invalid where notice issued beyond four years rested on alleged non-disclosure of prior period expenses, because the assessment record showed repeated queries, full particulars, vouchers and explanations had been furnished, and the Assessing Officer had already applied his mind in the original section 143(3) assessment. On those facts, reopening amounted to a mere change of opinion and was not saved by Explanation 1 to section 147, since the issue had been specifically examined rather than left to passive record production. The reassessment was therefore without jurisdiction for want of failure to make a full and true disclosure. en-us Wed, 20 Jan 2010 00:00:00 +0530 Thu, 31 Jan 2013 18:38:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=35247 Reassessment under sections 147/148 was treated as invalid where notice issued beyond four years rested on alleged non-disclosure of prior period expenses, because the assessment record showed repeated queries, full particulars, vouchers and explanations had been furnished, and the Assessing Officer had already applied his mind in the original section 143(3) assessment. On those facts, reopening amounted to a mere change of opinion and was not saved by Explanation 1 to section 147, since the issue had been specifically examined rather than left to passive record production. The reassessment was therefore without jurisdiction for want of failure to make a full and true disclosure. Case-Laws Income Tax Wed, 20 Jan 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=35247