https://www.taxtmi.com/caselaws?id=450257 Reassessment notices issued beyond four years from the end of the assessment year under Section 147 are valid only if escaped income is attributable to the assessee's failure to disclose fully and truly all material facts necessary for assessment. Here, the reopening rested on a later view that the Section 10B exemption had been wrongly allowed, but there was no material showing suppression of approvals or other relevant facts by the assessees. A later legal interpretation or a different inference from the same record cannot by itself justify reopening after the statutory four-year bar. The reassessment proceedings and consequential assessment orders were therefore incompetent and were set aside. en-us Thu, 12 Oct 2023 00:00:00 +0530 Fri, 01 Mar 2024 07:32:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=450257 Reassessment notices issued beyond four years from the end of the assessment year under Section 147 are valid only if escaped income is attributable to the assessee's failure to disclose fully and truly all material facts necessary for assessment. Here, the reopening rested on a later view that the Section 10B exemption had been wrongly allowed, but there was no material showing suppression of approvals or other relevant facts by the assessees. A later legal interpretation or a different inference from the same record cannot by itself justify reopening after the statutory four-year bar. The reassessment proceedings and consequential assessment orders were therefore incompetent and were set aside. Case-Laws Income Tax Thu, 12 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=450257