https://www.taxtmi.com/caselaws?id=766002 Reassessment beyond four years from the end of the assessment year required the recorded reasons to allege a failure by the assessee to fully and truly disclose all material facts necessary for assessment. As the reasons did not contain that jurisdictional allegation, and the record showed consistent disclosure in the return and prior correspondence, reopening was invalid. A later year's assessment could not cure the missing jurisdictional basis for the earlier year, and a change in tax treatment for later years did not remove the statutory requirement. The notice and consequential rejection of objections were therefore quashed. en-us Tue, 11 Feb 2025 00:00:00 +0530 Fri, 14 Feb 2025 08:26:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=766002 Reassessment beyond four years from the end of the assessment year required the recorded reasons to allege a failure by the assessee to fully and truly disclose all material facts necessary for assessment. As the reasons did not contain that jurisdictional allegation, and the record showed consistent disclosure in the return and prior correspondence, reopening was invalid. A later year's assessment could not cure the missing jurisdictional basis for the earlier year, and a change in tax treatment for later years did not remove the statutory requirement. The notice and consequential rejection of objections were therefore quashed. Case-Laws Income Tax Tue, 11 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=766002