https://www.taxtmi.com/caselaws?id=785358 Reopening of assessment and validity of notice issuance were upheld where the Assessing Officer had jurisdiction under the administrative allocation and the assessee failed to prove lack of jurisdiction; consequence: jurisdictional objection dismissed. Reopening beyond four years was held valid because specific information from the Investigation Wing about undisclosed manipulation furnished a prima facie belief of escapement of income, not a mere change of opinion; consequence: reassessment beyond four years sustained. The proviso conditions to reopening were satisfied due to non-disclosure of the true character of transactions; consequence: reassessment valid. On the claim of fictitious loss, factual reconciliation was necessary; consequence: matter remanded to the AO for de novo transaction-wise verification. en-us Tue, 30 Dec 2025 00:00:00 +0530 Thu, 22 Jan 2026 08:41:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785358 Reopening of assessment and validity of notice issuance were upheld where the Assessing Officer had jurisdiction under the administrative allocation and the assessee failed to prove lack of jurisdiction; consequence: jurisdictional objection dismissed. Reopening beyond four years was held valid because specific information from the Investigation Wing about undisclosed manipulation furnished a prima facie belief of escapement of income, not a mere change of opinion; consequence: reassessment beyond four years sustained. The proviso conditions to reopening were satisfied due to non-disclosure of the true character of transactions; consequence: reassessment valid. On the claim of fictitious loss, factual reconciliation was necessary; consequence: matter remanded to the AO for de novo transaction-wise verification. Case-Laws Income Tax Tue, 30 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785358