https://www.taxtmi.com/caselaws?id=783729 Reassessment initiated after four years from the end of the relevant AY, where the original return had been scrutinised under s. 143(3), is sustainable only if the AO records in the reasons that income escaped assessment due to the assessee's failure to disclose fully and truly all material facts, as mandated by the first proviso to s. 147. The extended limitation under s. 149(1)(b) cannot be invoked to bypass the proviso where the case falls within its ambit. As the recorded reasons did not document any such specific failure of disclosure, the assumption of jurisdiction under s. 147 was invalid and the notice under s. 148 was quashed, allowing the assessee's challenge. en-us Thu, 30 Oct 2025 00:00:00 +0530 Mon, 22 Dec 2025 07:49:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783729 Reassessment initiated after four years from the end of the relevant AY, where the original return had been scrutinised under s. 143(3), is sustainable only if the AO records in the reasons that income escaped assessment due to the assessee's failure to disclose fully and truly all material facts, as mandated by the first proviso to s. 147. The extended limitation under s. 149(1)(b) cannot be invoked to bypass the proviso where the case falls within its ambit. As the recorded reasons did not document any such specific failure of disclosure, the assumption of jurisdiction under s. 147 was invalid and the notice under s. 148 was quashed, allowing the assessee's challenge. Case-Laws Income Tax Thu, 30 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783729