https://www.taxtmi.com/caselaws?id=771514 Reopening of assessment beyond four years from the end of the relevant assessment year is barred unless the assessee failed to disclose fully and truly all material facts. Here, the original return and the relevant transaction details were already before the AO in the earlier proceedings, and no such failure by the assessee was shown. The recorded reasons had to stand on their own and could not be supported by extraneous material. Since the statutory condition for reopening under the first proviso to section 147 was not met, the reassessment proceedings were held invalid and quashed in favour of the assessee. en-us Wed, 23 Apr 2025 00:00:00 +0530 Tue, 27 May 2025 08:32:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=771514 Reopening of assessment beyond four years from the end of the relevant assessment year is barred unless the assessee failed to disclose fully and truly all material facts. Here, the original return and the relevant transaction details were already before the AO in the earlier proceedings, and no such failure by the assessee was shown. The recorded reasons had to stand on their own and could not be supported by extraneous material. Since the statutory condition for reopening under the first proviso to section 147 was not met, the reassessment proceedings were held invalid and quashed in favour of the assessee. Case-Laws Income Tax Wed, 23 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=771514