https://www.taxtmi.com/caselaws?id=784157 Reopening under s.147 was upheld because the AO recorded that the taxpayer had failed to fully and truly disclose material facts, constituting a valid "reason to believe" based on tangible material; since the matters reopened were not examined in the earlier scrutiny under s.143(3), the reassessment was not barred as a mere change of opinion, and the challenge to jurisdiction failed. The remand by the first appellate authority was sustained as a proper exercise of power under s.251(1)(a), where the assessment had been completed without reasons on alleged non-compliance and the taxpayer explained inability to respond due to illness; the direction for a de novo assessment was affirmed and the appeal grounds were dismissed. en-us Fri, 24 Oct 2025 00:00:00 +0530 Tue, 30 Dec 2025 09:29:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784157 Reopening under s.147 was upheld because the AO recorded that the taxpayer had failed to fully and truly disclose material facts, constituting a valid "reason to believe" based on tangible material; since the matters reopened were not examined in the earlier scrutiny under s.143(3), the reassessment was not barred as a mere change of opinion, and the challenge to jurisdiction failed. The remand by the first appellate authority was sustained as a proper exercise of power under s.251(1)(a), where the assessment had been completed without reasons on alleged non-compliance and the taxpayer explained inability to respond due to illness; the direction for a de novo assessment was affirmed and the appeal grounds were dismissed. Case-Laws Income Tax Fri, 24 Oct 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784157