https://www.taxtmi.com/caselaws?id=778824 ITAT held that reopening of assessment beyond four years was invalid where the AO possessed no new tangible material arising after the original 143(3) order; the reasons recorded merely reiterated information already on file (return, P&L, balance sheet, expense documents) used in the original assessment. Because the first proviso to s.147 was not satisfied and there was no allegation that the taxpayer withheld relevant material, the reassessment notice was without jurisdiction, the reopening was quashed, and the appeal was allowed. en-us Thu, 18 Sep 2025 00:00:00 +0530 Tue, 23 Sep 2025 08:29:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=778824 ITAT held that reopening of assessment beyond four years was invalid where the AO possessed no new tangible material arising after the original 143(3) order; the reasons recorded merely reiterated information already on file (return, P&L, balance sheet, expense documents) used in the original assessment. Because the first proviso to s.147 was not satisfied and there was no allegation that the taxpayer withheld relevant material, the reassessment notice was without jurisdiction, the reopening was quashed, and the appeal was allowed. Case-Laws Income Tax Thu, 18 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=778824