https://www.taxtmi.com/caselaws?id=462898 Reassessment initiated beyond four years from the end of the assessment year requires the Assessing Officer to establish that income escaped assessment because the assessee failed to fully and truly disclose all material facts. Where the issue had already been examined in the original scrutiny assessment through a questionnaire and the assessee had furnished its explanation, reopening on the same material is a change of opinion. In the absence of fresh tangible material or a recorded basis showing nondisclosure, the jurisdictional condition under the proviso to section 147 is not met, and the reopening is invalid. en-us Wed, 23 Apr 2025 00:00:00 +0530 Tue, 22 Jul 2025 11:58:05 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462898 Reassessment initiated beyond four years from the end of the assessment year requires the Assessing Officer to establish that income escaped assessment because the assessee failed to fully and truly disclose all material facts. Where the issue had already been examined in the original scrutiny assessment through a questionnaire and the assessee had furnished its explanation, reopening on the same material is a change of opinion. In the absence of fresh tangible material or a recorded basis showing nondisclosure, the jurisdictional condition under the proviso to section 147 is not met, and the reopening is invalid. Case-Laws Income Tax Wed, 23 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462898