https://www.taxtmi.com/caselaws?id=789843 Where a reassessment notice is issued more than four years after the end of the relevant assessment year, jurisdiction under section 147 requires fresh tangible material and a specific failure by the assessee to disclose fully and truly all material facts. The recorded reasons in this matter relied only on a reappraisal of material already on record, including disclosure of interest income on HUDCO bonds for deduction under section 36(1)(viii), and identified no undisclosed material fact. The reopening was therefore treated as an impermissible change of opinion, and the reassessment as well as the consequential assessment order were quashed. en-us Thu, 02 Apr 2026 00:00:00 +0530 Wed, 15 Apr 2026 09:05:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789843 Where a reassessment notice is issued more than four years after the end of the relevant assessment year, jurisdiction under section 147 requires fresh tangible material and a specific failure by the assessee to disclose fully and truly all material facts. The recorded reasons in this matter relied only on a reappraisal of material already on record, including disclosure of interest income on HUDCO bonds for deduction under section 36(1)(viii), and identified no undisclosed material fact. The reopening was therefore treated as an impermissible change of opinion, and the reassessment as well as the consequential assessment order were quashed. Case-Laws Income Tax Thu, 02 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789843