https://www.taxtmi.com/caselaws?id=461577 Reopening of assessment beyond four years was treated as barred where the assessee had already disclosed the External Development Charges in the balance sheet and during original scrutiny, and the Assessing Officer relied on the same material without any new tangible evidence. On those facts, the first proviso to Section 147 applied because there was no failure to fully and truly disclose material facts. The reassessment was therefore regarded as a mere change of opinion, and the consequential additions could not be sustained. en-us Tue, 22 May 2018 00:00:00 +0530 Sat, 12 Apr 2025 11:25:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=461577 Reopening of assessment beyond four years was treated as barred where the assessee had already disclosed the External Development Charges in the balance sheet and during original scrutiny, and the Assessing Officer relied on the same material without any new tangible evidence. On those facts, the first proviso to Section 147 applied because there was no failure to fully and truly disclose material facts. The reassessment was therefore regarded as a mere change of opinion, and the consequential additions could not be sustained. Case-Laws Income Tax Tue, 22 May 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=461577