https://www.taxtmi.com/caselaws?id=779227 ITAT (DELHI - AT) held that a second reopening beyond four years was invalid because the recorded reasons failed to identify specific material showing the assessee did not disclose all relevant facts originally. Relying on HC authority that reopening reasons must stand on their face and cannot be amended or supplemented, the Tribunal found the AO's reasons insufficient under the first proviso to section 147 and quashed the reopening and resultant addition under section 68. en-us Mon, 20 Jan 2025 00:00:00 +0530 Wed, 01 Oct 2025 09:07:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=779227 ITAT (DELHI - AT) held that a second reopening beyond four years was invalid because the recorded reasons failed to identify specific material showing the assessee did not disclose all relevant facts originally. Relying on HC authority that reopening reasons must stand on their face and cannot be amended or supplemented, the Tribunal found the AO's reasons insufficient under the first proviso to section 147 and quashed the reopening and resultant addition under section 68. Case-Laws Income Tax Mon, 20 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=779227