https://www.taxtmi.com/caselaws?id=772859 A reassessment under section 147 initiated after four years from the end of the relevant assessment year is invalid where the original assessment was completed under section 143(3) on scrutiny and no fresh tangible material is shown. Reopening on a reappraisal of the same balance-sheet details and expenditure claims already examined in the original proceedings amounts to impermissible reconsideration. In the absence of any failure by the assessee to fully and truly disclose material facts, the first proviso to section 147 bars the reassessment. The reassessment notice and order were therefore quashed in favour of the assessee. en-us Mon, 09 Jun 2025 00:00:00 +0530 Sat, 14 Jun 2025 06:47:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=772859 A reassessment under section 147 initiated after four years from the end of the relevant assessment year is invalid where the original assessment was completed under section 143(3) on scrutiny and no fresh tangible material is shown. Reopening on a reappraisal of the same balance-sheet details and expenditure claims already examined in the original proceedings amounts to impermissible reconsideration. In the absence of any failure by the assessee to fully and truly disclose material facts, the first proviso to section 147 bars the reassessment. The reassessment notice and order were therefore quashed in favour of the assessee. Case-Laws Income Tax Mon, 09 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=772859