https://www.taxtmi.com/caselaws?id=465816 Reassessment notices issued after completed assessments were challenged as lacking the statutory preconditions under ss. 147/148, IT Act, particularly the twin requirements of "reason to believe" and assessee's failure to disclose fully and truly all material facts where reopening is beyond four years. The HC held the AO lacked jurisdiction because the recorded reasons did not satisfy these conditions, and the Revenue could not cure the defect by filing additional affidavits or supplementing material beyond the recorded reasons; consequently, the notices and orders rejecting objections were quashed. In appeal, the SC dismissed the SLP due to an unexplained 501-day delay and, independently, declined interference on merits. en-us Fri, 26 Apr 2024 00:00:00 +0530 Fri, 09 Jan 2026 19:03:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465816 Reassessment notices issued after completed assessments were challenged as lacking the statutory preconditions under ss. 147/148, IT Act, particularly the twin requirements of "reason to believe" and assessee's failure to disclose fully and truly all material facts where reopening is beyond four years. The HC held the AO lacked jurisdiction because the recorded reasons did not satisfy these conditions, and the Revenue could not cure the defect by filing additional affidavits or supplementing material beyond the recorded reasons; consequently, the notices and orders rejecting objections were quashed. In appeal, the SC dismissed the SLP due to an unexplained 501-day delay and, independently, declined interference on merits. Case-Laws Income Tax Fri, 26 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465816