https://www.taxtmi.com/caselaws?id=766162 A reassessment notice issued beyond four years from the end of the assessment year cannot be sustained unless the recorded reasons themselves clearly identify the material facts allegedly not fully and truly disclosed by the assessee. The first proviso to Section 147 requires a specific, reasoned assertion of failure to disclose, and that requirement cannot be cured by later affidavit or oral submissions. Because the recorded reasons did not specify the withheld facts, the reopening failed on its own terms and the reassessment notice was quashed. en-us Mon, 10 Feb 2025 00:00:00 +0530 Wed, 19 Feb 2025 08:42:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=766162 A reassessment notice issued beyond four years from the end of the assessment year cannot be sustained unless the recorded reasons themselves clearly identify the material facts allegedly not fully and truly disclosed by the assessee. The first proviso to Section 147 requires a specific, reasoned assertion of failure to disclose, and that requirement cannot be cured by later affidavit or oral submissions. Because the recorded reasons did not specify the withheld facts, the reopening failed on its own terms and the reassessment notice was quashed. Case-Laws Income Tax Mon, 10 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=766162