https://www.taxtmi.com/caselaws?id=788113 Reopening of assessment beyond four years was held invalid because the recorded reasons did not expressly allege that the assessee failed to disclose fully and truly all material facts, a jurisdictional requirement under the first proviso to Section 147; the notice under Section 148 was therefore quashed. Disallowance of partner remuneration was also found unsustainable because the partnership deed was in writing and specified the partners' shares, satisfying Section 184, and registration of the deed with any external authority was not a statutory condition for recognition of the firm. The assessment and consequential proceedings were annulled. en-us Thu, 19 Feb 2026 00:00:00 +0530 Tue, 17 Mar 2026 08:23:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=788113 Reopening of assessment beyond four years was held invalid because the recorded reasons did not expressly allege that the assessee failed to disclose fully and truly all material facts, a jurisdictional requirement under the first proviso to Section 147; the notice under Section 148 was therefore quashed. Disallowance of partner remuneration was also found unsustainable because the partnership deed was in writing and specified the partners' shares, satisfying Section 184, and registration of the deed with any external authority was not a statutory condition for recognition of the firm. The assessment and consequential proceedings were annulled. Case-Laws Income Tax Thu, 19 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=788113