https://www.taxtmi.com/caselaws?id=790122 A reassessment notice issued beyond four years after scrutiny assessment was held invalid because the recorded reasons did not show failure by the assessee to fully and truly disclose all material facts. The AO had already sought and accepted details of unsecured loans in the original Section 143(3) assessment, and the reopening reasons relied only on general survey information without identifying the specific lenders, loans, or disclosure lapse. As the first proviso to Section 147 applied, the reasons had to independently establish the statutory condition for reopening and could not be supplemented later by notices, objections orders, or affidavits. On the material available, the loans were documented, routed through banking channels, and repaid, so the Section 148 notice was quashed. en-us Tue, 07 Apr 2026 00:00:00 +0530 Mon, 20 Apr 2026 08:30:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790122 A reassessment notice issued beyond four years after scrutiny assessment was held invalid because the recorded reasons did not show failure by the assessee to fully and truly disclose all material facts. The AO had already sought and accepted details of unsecured loans in the original Section 143(3) assessment, and the reopening reasons relied only on general survey information without identifying the specific lenders, loans, or disclosure lapse. As the first proviso to Section 147 applied, the reasons had to independently establish the statutory condition for reopening and could not be supplemented later by notices, objections orders, or affidavits. On the material available, the loans were documented, routed through banking channels, and repaid, so the Section 148 notice was quashed. Case-Laws Income Tax Tue, 07 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790122