https://www.taxtmi.com/caselaws?id=468090 Reassessment notice issued beyond four years was invalid where it was based on the same valuation, exchange-loss, write-back and set-off material already examined in the original assessment. The reopening amounted to a mere change of opinion, and the first proviso to section 147 required a demonstrable failure by the assessee to disclose fully and truly all material facts necessary for assessment. No such failure was recorded or established. The reassessment was therefore without jurisdiction and the reassessment order was quashed in favour of the assessee. en-us Thu, 13 Feb 2025 00:00:00 +0530 Wed, 15 Apr 2026 20:22:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468090 Reassessment notice issued beyond four years was invalid where it was based on the same valuation, exchange-loss, write-back and set-off material already examined in the original assessment. The reopening amounted to a mere change of opinion, and the first proviso to section 147 required a demonstrable failure by the assessee to disclose fully and truly all material facts necessary for assessment. No such failure was recorded or established. The reassessment was therefore without jurisdiction and the reassessment order was quashed in favour of the assessee. Case-Laws Income Tax Thu, 13 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468090