https://www.taxtmi.com/caselaws?id=767622 A reassessment notice issued after four years from the end of the relevant assessment year is valid only if the recorded reasons show that the assessee failed to fully and truly disclose all material facts necessary for assessment. Here, the assessment had been completed under section 143(3), and the recorded reasons themselves referred to disclosures already made in the return, financial statements, annual report, and earlier scrutiny proceedings. Because the order rejecting objections did not answer the specific challenge on disclosure failure, the jurisdictional condition under the first proviso to section 147 was not met and the reopening was held without jurisdiction. en-us Mon, 10 Mar 2025 00:00:00 +0530 Fri, 21 Mar 2025 08:25:49 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767622 A reassessment notice issued after four years from the end of the relevant assessment year is valid only if the recorded reasons show that the assessee failed to fully and truly disclose all material facts necessary for assessment. Here, the assessment had been completed under section 143(3), and the recorded reasons themselves referred to disclosures already made in the return, financial statements, annual report, and earlier scrutiny proceedings. Because the order rejecting objections did not answer the specific challenge on disclosure failure, the jurisdictional condition under the first proviso to section 147 was not met and the reopening was held without jurisdiction. Case-Laws Income Tax Mon, 10 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767622