https://www.taxtmi.com/caselaws?id=786942 Reopening an assessment after four years is permissible only where the statutory proviso and its Explanation validate that income escaped assessment due to failure to file a return in response to specified notices or failure to disclose fully and truly all material facts. The court found the assessee had furnished specific documentary disclosure-court order for capital reduction, certified minutes, ledger entries, remittance and share certificates, tax residence certificates and a tabulation of payments-during original scrutiny, and that the reassessment appeared to stem from change of opinion or external information rather than nondisclosure. Consequently the notices for reopening were quashed and reassessment held unjustified. en-us Fri, 06 Feb 2026 00:00:00 +0530 Mon, 23 Feb 2026 07:38:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786942 Reopening an assessment after four years is permissible only where the statutory proviso and its Explanation validate that income escaped assessment due to failure to file a return in response to specified notices or failure to disclose fully and truly all material facts. The court found the assessee had furnished specific documentary disclosure-court order for capital reduction, certified minutes, ledger entries, remittance and share certificates, tax residence certificates and a tabulation of payments-during original scrutiny, and that the reassessment appeared to stem from change of opinion or external information rather than nondisclosure. Consequently the notices for reopening were quashed and reassessment held unjustified. Case-Laws Income Tax Fri, 06 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786942