https://www.taxtmi.com/caselaws?id=772282 Reassessment after four years from a completed assessment under section 143(3) requires the Revenue to establish failure by the assessee to fully and truly disclose material facts, together with valid sanction under section 151(1). Where the recorded reasons show only reappraisal of material already on record and no fresh tangible material, the reopening amounts to an impermissible change of opinion. On these facts, the reassessment notice and proceedings were invalid, the consequential addition could not survive, and the completed assessment was set aside. en-us Fri, 30 May 2025 00:00:00 +0530 Fri, 06 Jun 2025 08:30:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=772282 Reassessment after four years from a completed assessment under section 143(3) requires the Revenue to establish failure by the assessee to fully and truly disclose material facts, together with valid sanction under section 151(1). Where the recorded reasons show only reappraisal of material already on record and no fresh tangible material, the reopening amounts to an impermissible change of opinion. On these facts, the reassessment notice and proceedings were invalid, the consequential addition could not survive, and the completed assessment was set aside. Case-Laws Income Tax Fri, 30 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=772282