https://www.taxtmi.com/caselaws?id=789899 Reassessment beyond four years was held invalid where the recorded reasons did not identify any failure by the assessee to fully and truly disclose material facts after an assessment under section 143(3). The Tribunal found that the reopening was based on borrowed information from the Investigation Wing about alleged client code modification, without independent application of mind or a live link between the material and escapement of income. Procedural defects, including non-furnishing of complete reasons and supporting material, absence of sanction material, and denial of effective opportunity, further vitiated the reassessment. The consequential assessment was therefore set aside in favour of the assessee. en-us Wed, 08 Apr 2026 00:00:00 +0530 Thu, 16 Apr 2026 08:34:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789899 Reassessment beyond four years was held invalid where the recorded reasons did not identify any failure by the assessee to fully and truly disclose material facts after an assessment under section 143(3). The Tribunal found that the reopening was based on borrowed information from the Investigation Wing about alleged client code modification, without independent application of mind or a live link between the material and escapement of income. Procedural defects, including non-furnishing of complete reasons and supporting material, absence of sanction material, and denial of effective opportunity, further vitiated the reassessment. The consequential assessment was therefore set aside in favour of the assessee. Case-Laws Income Tax Wed, 08 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789899