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    <title>2026 (4) TMI 46 - ITAT DELHI</title>
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    <description>Reassessment beyond four years requires a demonstrable failure by the assessee to make full and true disclosure of material facts, and it cannot rest on mere reappraisal of the existing record or a change of opinion; on the facts recorded, the reopening was therefore invalid. A capital gains exemption linked to investment in a residential house remained allowable where the relevant computation and investment details were already disclosed during original assessment, and the claim could be examined on the existing material. Receipts supported by evidence of agricultural operations and lease of agricultural land were not correctly treated as income from other sources, so the related addition was unsustainable.</description>
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      <link>https://www.taxtmi.com/caselaws?id=788977</link>
      <description>Reassessment beyond four years requires a demonstrable failure by the assessee to make full and true disclosure of material facts, and it cannot rest on mere reappraisal of the existing record or a change of opinion; on the facts recorded, the reopening was therefore invalid. A capital gains exemption linked to investment in a residential house remained allowable where the relevant computation and investment details were already disclosed during original assessment, and the claim could be examined on the existing material. Receipts supported by evidence of agricultural operations and lease of agricultural land were not correctly treated as income from other sources, so the related addition was unsustainable.</description>
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