https://www.taxtmi.com/caselaws?id=787513 Reopening an assessment beyond four years under section 147 requires the recorded reasons to specifically identify the assessee's failure to disclose fully and truly all material facts; reopening based only on Investigation Wing information, without independent verification by the Assessing Officer, is invalid. A notice under section 148 is also jurisdictionally defective where it is issued by an officer lacking territorial jurisdiction and no transfer order under section 127 is shown. On these grounds, the reassessment proceedings were quashed and the assessee succeeded. en-us Wed, 18 Feb 2026 00:00:00 +0530 Thu, 05 Mar 2026 14:13:37 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787513 Reopening an assessment beyond four years under section 147 requires the recorded reasons to specifically identify the assessee's failure to disclose fully and truly all material facts; reopening based only on Investigation Wing information, without independent verification by the Assessing Officer, is invalid. A notice under section 148 is also jurisdictionally defective where it is issued by an officer lacking territorial jurisdiction and no transfer order under section 127 is shown. On these grounds, the reassessment proceedings were quashed and the assessee succeeded. Case-Laws Income Tax Wed, 18 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787513