https://www.taxtmi.com/caselaws?id=785869 Reassessment beyond four years was barred because the recorded reasons and section 148A(d) order did not allege that the assessee failed to disclose fully and truly all material facts, which was fatal to jurisdiction under the proviso to section 147. Notice under section 148 was also invalid because it was issued by the Jurisdictional Assessing Officer instead of through the faceless allocation mechanism under section 151A and the applicable scheme, rendering the reopening void ab initio. An addition under section 69A based only on an unsigned third-party excel sheet, without corroboration, cross-examination, or proper electronic evidence compliance, was unsustainable. A section 143(2) notice was not invalid merely because it did not specify the scrutiny category, as the CBDT instruction was treated as administrative. en-us Wed, 21 Jan 2026 00:00:00 +0530 Thu, 29 Jan 2026 17:30:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785869 Reassessment beyond four years was barred because the recorded reasons and section 148A(d) order did not allege that the assessee failed to disclose fully and truly all material facts, which was fatal to jurisdiction under the proviso to section 147. Notice under section 148 was also invalid because it was issued by the Jurisdictional Assessing Officer instead of through the faceless allocation mechanism under section 151A and the applicable scheme, rendering the reopening void ab initio. An addition under section 69A based only on an unsigned third-party excel sheet, without corroboration, cross-examination, or proper electronic evidence compliance, was unsustainable. A section 143(2) notice was not invalid merely because it did not specify the scrutiny category, as the CBDT instruction was treated as administrative. Case-Laws Income Tax Wed, 21 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785869