https://www.taxtmi.com/caselaws?id=459287 Notices issued under Section 148 were quashed because the Assessing Officer relied on material (related party loans, shareholding particulars, audit notes) that had been disclosed and considered in the original scrutiny assessment; the court applied the post 1989 'reason to believe' standard and held reopening beyond the statutory time limit requires failure to disclose truly and fully all material facts, which was not shown, and therefore the proviso to Section 147 was not satisfied and reassessment was invalid. en-us Mon, 25 Sep 2023 00:00:00 +0530 Thu, 12 Mar 2026 15:47:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=459287 Notices issued under Section 148 were quashed because the Assessing Officer relied on material (related party loans, shareholding particulars, audit notes) that had been disclosed and considered in the original scrutiny assessment; the court applied the post 1989 'reason to believe' standard and held reopening beyond the statutory time limit requires failure to disclose truly and fully all material facts, which was not shown, and therefore the proviso to Section 147 was not satisfied and reassessment was invalid. Case-Laws Income Tax Mon, 25 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=459287