https://www.taxtmi.com/caselaws?id=786905 Reopening assessments beyond four years is permissible only on demonstrable failure to disclose fully and truly; ambiguous reasons or a mere change of opinion render reassessment invalid. Material relied upon must have a direct nexus with the taxpayer and be furnished at the stage-appropriate disclosure step; absence of specific tangible material linking the taxpayer to alleged manipulation vitiates the reopening. Where purchase, sale and allotment of mutual fund units and dividend credit through banking channels are accepted as genuine in part, and no cogent evidence of collusion or sham exists, treating the dividend as an unexplained cash credit is unsustainable and the addition must be deleted. en-us Thu, 19 Feb 2026 00:00:00 +0530 Sat, 21 Feb 2026 09:29:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786905 Reopening assessments beyond four years is permissible only on demonstrable failure to disclose fully and truly; ambiguous reasons or a mere change of opinion render reassessment invalid. Material relied upon must have a direct nexus with the taxpayer and be furnished at the stage-appropriate disclosure step; absence of specific tangible material linking the taxpayer to alleged manipulation vitiates the reopening. Where purchase, sale and allotment of mutual fund units and dividend credit through banking channels are accepted as genuine in part, and no cogent evidence of collusion or sham exists, treating the dividend as an unexplained cash credit is unsustainable and the addition must be deleted. Case-Laws Income Tax Thu, 19 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786905