https://www.taxtmi.com/caselaws?id=783384 ITAT Chandigarh (AT) held that reassessment initiated u/s 147 beyond four years from the end of the relevant assessment year, where the original assessment was completed u/s 143(3), is invalid in absence of a recorded "jurisdictional fact" of failure by the assessee to truly and fully disclose all material facts. The Tribunal reiterated that, for invoking the extended period under the proviso to s.147, the AO must expressly demonstrate one of the specified circumstances, including such disclosure failure. As the reasons recorded did not establish this jurisdictional fact, the reopening proceedings were vitiated in law and quashed, deciding in favour of the assessee. en-us Wed, 10 Dec 2025 00:00:00 +0530 Sat, 13 Dec 2025 09:55:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783384 ITAT Chandigarh (AT) held that reassessment initiated u/s 147 beyond four years from the end of the relevant assessment year, where the original assessment was completed u/s 143(3), is invalid in absence of a recorded "jurisdictional fact" of failure by the assessee to truly and fully disclose all material facts. The Tribunal reiterated that, for invoking the extended period under the proviso to s.147, the AO must expressly demonstrate one of the specified circumstances, including such disclosure failure. As the reasons recorded did not establish this jurisdictional fact, the reopening proceedings were vitiated in law and quashed, deciding in favour of the assessee. Case-Laws Income Tax Wed, 10 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783384