https://www.taxtmi.com/caselaws?id=788742 Reopening of assessment beyond four years under the Income-tax Act, 1961 requires the Revenue to show both a failure by the assessee to disclose fully and truly all material facts and the existence of new tangible material, especially where the original assessment was completed under Section 143(3). The recorded reasons here rested on material already available in the assessment record and annual accounts, with no fresh material emerging after the original scrutiny. On that basis, the reassessment amounted only to a reappraisal of the same facts and was treated as a change of opinion. The reopening was therefore invalid and the reassessment could not be sustained for want of jurisdiction. en-us Tue, 17 Mar 2026 00:00:00 +0530 Fri, 27 Mar 2026 08:52:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=788742 Reopening of assessment beyond four years under the Income-tax Act, 1961 requires the Revenue to show both a failure by the assessee to disclose fully and truly all material facts and the existence of new tangible material, especially where the original assessment was completed under Section 143(3). The recorded reasons here rested on material already available in the assessment record and annual accounts, with no fresh material emerging after the original scrutiny. On that basis, the reassessment amounted only to a reappraisal of the same facts and was treated as a change of opinion. The reopening was therefore invalid and the reassessment could not be sustained for want of jurisdiction. Case-Laws Income Tax Tue, 17 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=788742