https://www.taxtmi.com/caselaws?id=757485 HC allowed the writ and quashed the proposed reassessment, holding the Revenue failed to establish that the assessee had not fully and truly disclosed material facts as required by the first proviso to s.147. The court noted client-code modifications by brokers are publicly known and, absent evidence that modifications were done under the assessee's instruction or that nondisclosure caused income to escape assessment, the statutory prerequisite for reopening after four years was missing. Reassessment could not be sustained merely on a generalized "reason to believe." en-us Fri, 23 Aug 2024 00:00:00 +0530 Wed, 15 Apr 2026 14:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=757485 HC allowed the writ and quashed the proposed reassessment, holding the Revenue failed to establish that the assessee had not fully and truly disclosed material facts as required by the first proviso to s.147. The court noted client-code modifications by brokers are publicly known and, absent evidence that modifications were done under the assessee's instruction or that nondisclosure caused income to escape assessment, the statutory prerequisite for reopening after four years was missing. Reassessment could not be sustained merely on a generalized "reason to believe." Case-Laws Income Tax Fri, 23 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=757485