https://www.taxtmi.com/caselaws?id=757601 The HC quashed a reassessment notice issued under Section 147 after finding jurisdictional facts absent. The reassessment was initiated in March 2021, five years after Assessment Year 2015-16 ended, beyond the four-year period. The court held that for reassessment after four years, the assessee must have failed to fully disclose material facts during original assessment. However, the original scrutiny assessment involved thorough examination with notices under Sections 143(2) and 142(1), detailed replies, and personal hearings. All four aspects cited for reassessment were facts already disclosed during original proceedings. The sanction under Section 151 was found arbitrary due to non-application of mind to Section 147's ingredients. The petition was decided in favor of the assessee. en-us Mon, 26 Aug 2024 00:00:00 +0530 Mon, 03 Mar 2025 12:06:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=757601 The HC quashed a reassessment notice issued under Section 147 after finding jurisdictional facts absent. The reassessment was initiated in March 2021, five years after Assessment Year 2015-16 ended, beyond the four-year period. The court held that for reassessment after four years, the assessee must have failed to fully disclose material facts during original assessment. However, the original scrutiny assessment involved thorough examination with notices under Sections 143(2) and 142(1), detailed replies, and personal hearings. All four aspects cited for reassessment were facts already disclosed during original proceedings. The sanction under Section 151 was found arbitrary due to non-application of mind to Section 147's ingredients. The petition was decided in favor of the assessee. Case-Laws Income Tax Mon, 26 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=757601