https://www.taxtmi.com/caselaws?id=467468 Reopening an income tax assessment after four years was held invalid because the reasons recorded did not allege that the assessee failed to disclose fully and truly all material facts; the proviso to the reopening rule requires an express, recorded allegation of nondisclosure and cannot be supported by subsequent affidavits or oral submissions. The tribunal noted that the assessee filed its return before the later judicial clarification on the rural classification relied upon by the assessing officer, and therefore the recorded reasons lacked the requisite disclosure failure foundation; consequence: the reassessment was quashed. en-us Thu, 20 Feb 2025 00:00:00 +0530 Thu, 19 Mar 2026 19:02:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467468 Reopening an income tax assessment after four years was held invalid because the reasons recorded did not allege that the assessee failed to disclose fully and truly all material facts; the proviso to the reopening rule requires an express, recorded allegation of nondisclosure and cannot be supported by subsequent affidavits or oral submissions. The tribunal noted that the assessee filed its return before the later judicial clarification on the rural classification relied upon by the assessing officer, and therefore the recorded reasons lacked the requisite disclosure failure foundation; consequence: the reassessment was quashed. Case-Laws Income Tax Thu, 20 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467468