https://www.taxtmi.com/caselaws?id=790722 Reassessment initiated after four years from the end of the relevant assessment year was invalid where the original section 143(3) assessment had already examined the section 35AD deduction and the recorded reasons did not identify any specific failure to disclose fully and truly all material facts. The first proviso to section 147 required such a disclosure failure for reopening, and a bare assertion was insufficient. Because the reopening relied on the same material already considered and amounted to a change of opinion, the reassessment notice and consequential orders were quashed. en-us Fri, 24 Apr 2026 00:00:00 +0530 Wed, 29 Apr 2026 12:39:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790722 Reassessment initiated after four years from the end of the relevant assessment year was invalid where the original section 143(3) assessment had already examined the section 35AD deduction and the recorded reasons did not identify any specific failure to disclose fully and truly all material facts. The first proviso to section 147 required such a disclosure failure for reopening, and a bare assertion was insufficient. Because the reopening relied on the same material already considered and amounted to a change of opinion, the reassessment notice and consequential orders were quashed. Case-Laws Income Tax Fri, 24 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790722