https://www.taxtmi.com/caselaws?id=467624 A reassessment notice issued beyond four years from the end of the assessment year is invalid unless the recorded reasons show that income escaped assessment because the assessee failed to disclose fully and truly all material facts necessary for assessment. Where the original assessment was completed under section 143(3), and the reopening relied only on material already available in the annual accounts without any new information coming to the Assessing Officer, the statutory condition for extended limitation is not met. A reopening on such grounds amounts to a mere change of opinion. The reassessment was therefore quashed and the invalidity of the reopening upheld in favour of the assessee. en-us Fri, 16 May 2025 00:00:00 +0530 Thu, 26 Mar 2026 19:09:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467624 A reassessment notice issued beyond four years from the end of the assessment year is invalid unless the recorded reasons show that income escaped assessment because the assessee failed to disclose fully and truly all material facts necessary for assessment. Where the original assessment was completed under section 143(3), and the reopening relied only on material already available in the annual accounts without any new information coming to the Assessing Officer, the statutory condition for extended limitation is not met. A reopening on such grounds amounts to a mere change of opinion. The reassessment was therefore quashed and the invalidity of the reopening upheld in favour of the assessee. Case-Laws Income Tax Fri, 16 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467624