https://www.taxtmi.com/caselaws?id=766036 A reassessment notice issued after four years is valid only if the recorded reasons themselves allege that the assessee failed to fully and truly disclose all material facts. Here, the reasons recorded contained no such allegation and relied on material already furnished during the original proceedings. The deduction issue had also been specifically queried, answered, and considered in the assessment order. On these facts, reopening on the same material was an impermissible review of the earlier assessment and amounted to a change of opinion. The HC therefore quashed the reassessment notice. en-us Tue, 11 Feb 2025 00:00:00 +0530 Sat, 15 Feb 2025 08:00:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=766036 A reassessment notice issued after four years is valid only if the recorded reasons themselves allege that the assessee failed to fully and truly disclose all material facts. Here, the reasons recorded contained no such allegation and relied on material already furnished during the original proceedings. The deduction issue had also been specifically queried, answered, and considered in the assessment order. On these facts, reopening on the same material was an impermissible review of the earlier assessment and amounted to a change of opinion. The HC therefore quashed the reassessment notice. Case-Laws Income Tax Tue, 11 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=766036