https://www.taxtmi.com/caselaws?id=784378 Where reassessment was initiated after four years from the end of the relevant AY following an assessment u/s 143(3), the AO was required under the proviso to s.147 to record in the reasons that income escaped assessment due to the assessee's failure to fully and truly disclose material facts; since no such satisfaction was recorded and the objection was met only by citing sanction, the reopening was held invalid and the s.148 notice and consequential assessment were quashed. The reasons also reflected borrowed satisfaction, merely reproducing investigation-wing information without any independent enquiry or live link to the belief of escapement; hence reopening was impermissible and was quashed. Further, objections were not disposed of by a speaking order as mandated; consequently, the reassessment was a nullity and was set aside, allowing the appeal. en-us Wed, 31 Dec 2025 00:00:00 +0530 Sat, 03 Jan 2026 08:03:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784378 Where reassessment was initiated after four years from the end of the relevant AY following an assessment u/s 143(3), the AO was required under the proviso to s.147 to record in the reasons that income escaped assessment due to the assessee's failure to fully and truly disclose material facts; since no such satisfaction was recorded and the objection was met only by citing sanction, the reopening was held invalid and the s.148 notice and consequential assessment were quashed. The reasons also reflected borrowed satisfaction, merely reproducing investigation-wing information without any independent enquiry or live link to the belief of escapement; hence reopening was impermissible and was quashed. Further, objections were not disposed of by a speaking order as mandated; consequently, the reassessment was a nullity and was set aside, allowing the appeal. Case-Laws Income Tax Wed, 31 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784378