https://www.taxtmi.com/caselaws?id=464301 Reassessment beyond four years under the first proviso to section 147 is valid only where the recorded reasons expressly show the assessee's failure to disclose fully and truly all material facts necessary for assessment. Where the original assessment under section 143(3) was completed on the basis of return, financial statements and inventory details already before the AO, and the reopening relied on the same material without identifying any withheld facts, the attempt amounts to a mere change of opinion and is without jurisdiction. On that reasoning, the reassessment notice under section 148 and the consequential assessment are invalid and liable to be quashed. en-us Mon, 26 Aug 2024 00:00:00 +0530 Wed, 15 Oct 2025 16:47:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=464301 Reassessment beyond four years under the first proviso to section 147 is valid only where the recorded reasons expressly show the assessee's failure to disclose fully and truly all material facts necessary for assessment. Where the original assessment under section 143(3) was completed on the basis of return, financial statements and inventory details already before the AO, and the reopening relied on the same material without identifying any withheld facts, the attempt amounts to a mere change of opinion and is without jurisdiction. On that reasoning, the reassessment notice under section 148 and the consequential assessment are invalid and liable to be quashed. Case-Laws Income Tax Mon, 26 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=464301