https://www.taxtmi.com/caselaws?id=788978 Reassessment initiated beyond four years from the end of the relevant assessment year required a recorded allegation that the assessee failed to fully and truly disclose all material facts necessary for assessment; without that jurisdictional averment, the reopening could not stand. The reasons recorded referred only to information from the Investigation Wing and did not state any failure by the assessee to disclose material facts. As the statutory condition under the first proviso to Section 147 was not satisfied, the reassessment was invalid and the order was quashed for want of jurisdiction. en-us Mon, 30 Mar 2026 00:00:00 +0530 Wed, 01 Apr 2026 07:51:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=788978 Reassessment initiated beyond four years from the end of the relevant assessment year required a recorded allegation that the assessee failed to fully and truly disclose all material facts necessary for assessment; without that jurisdictional averment, the reopening could not stand. The reasons recorded referred only to information from the Investigation Wing and did not state any failure by the assessee to disclose material facts. As the statutory condition under the first proviso to Section 147 was not satisfied, the reassessment was invalid and the order was quashed for want of jurisdiction. Case-Laws Income Tax Mon, 30 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=788978