https://www.taxtmi.com/caselaws?id=464937 HC quashed the reassessment proceedings initiated under Sections 147/148 as the notice was issued beyond four years from the end of the relevant assessment year, despite an assessment under Section 143(3) having already been completed. The HC held that the proviso to Section 147 applied, requiring the Revenue to show failure by the assessee to fully and truly disclose all material facts. As the issue sought to be reopened had already been considered in the original assessment and no such failure was demonstrated, the reopening was held invalid and the notice under Section 148 was set aside. en-us Thu, 07 Mar 2024 00:00:00 +0530 Mon, 24 Nov 2025 18:58:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=464937 HC quashed the reassessment proceedings initiated under Sections 147/148 as the notice was issued beyond four years from the end of the relevant assessment year, despite an assessment under Section 143(3) having already been completed. The HC held that the proviso to Section 147 applied, requiring the Revenue to show failure by the assessee to fully and truly disclose all material facts. As the issue sought to be reopened had already been considered in the original assessment and no such failure was demonstrated, the reopening was held invalid and the notice under Section 148 was set aside. Case-Laws Income Tax Thu, 07 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=464937