https://www.taxtmi.com/caselaws?id=777124 Reassessment under sections 147 and 148 requires recorded reasons showing that the assessee failed to disclose fully and truly all material facts, especially where the original assessment was completed under section 143(3). In the absence of a clear recorded satisfaction on that jurisdictional requirement under the first proviso to section 147, the reopening cannot be sustained in law. On the facts stated, the reopening was invalid and the reassessment was quashed. en-us Wed, 08 Jan 2025 00:00:00 +0530 Mon, 25 Aug 2025 08:40:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=777124 Reassessment under sections 147 and 148 requires recorded reasons showing that the assessee failed to disclose fully and truly all material facts, especially where the original assessment was completed under section 143(3). In the absence of a clear recorded satisfaction on that jurisdictional requirement under the first proviso to section 147, the reopening cannot be sustained in law. On the facts stated, the reopening was invalid and the reassessment was quashed. Case-Laws Income Tax Wed, 08 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=777124