https://www.taxtmi.com/caselaws?id=781767 ITAT Delhi allowed the assessee's appeals and quashed the reassessment proceedings. It held that the notice issued under s.148, having been issued beyond four years from the end of the relevant assessment years, was governed by the first proviso to s.147. The recorded reasons did not allege any failure by the assessee to fully and truly disclose all material facts necessary for assessment, a mandatory jurisdictional requirement in such cases. Relying on its earlier decision in the assessee's own case for AY 2005-06, the Tribunal invalidated the reopening. en-us Fri, 26 Sep 2025 00:00:00 +0530 Thu, 20 Nov 2025 08:42:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=781767 ITAT Delhi allowed the assessee's appeals and quashed the reassessment proceedings. It held that the notice issued under s.148, having been issued beyond four years from the end of the relevant assessment years, was governed by the first proviso to s.147. The recorded reasons did not allege any failure by the assessee to fully and truly disclose all material facts necessary for assessment, a mandatory jurisdictional requirement in such cases. Relying on its earlier decision in the assessee's own case for AY 2005-06, the Tribunal invalidated the reopening. Case-Laws Income Tax Fri, 26 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=781767