https://www.taxtmi.com/caselaws?id=790896 Reassessment initiated beyond four years from the end of the relevant assessment year requires the recorded reasons to specifically allege that escapement of income arose from the assessee's failure to fully and truly disclose all material facts. Where the original assessment was completed under section 143(3) after examination of the disputed claim, and the reopening rested on material already on record with no fresh tangible material, the notice is invalid. A reopening based on audit objection and a mere change of opinion is not legally sustainable; the reassessment notice and resulting order were quashed in favour of the assessee. en-us Wed, 29 Apr 2026 00:00:00 +0530 Sat, 02 May 2026 07:40:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790896 Reassessment initiated beyond four years from the end of the relevant assessment year requires the recorded reasons to specifically allege that escapement of income arose from the assessee's failure to fully and truly disclose all material facts. Where the original assessment was completed under section 143(3) after examination of the disputed claim, and the reopening rested on material already on record with no fresh tangible material, the notice is invalid. A reopening based on audit objection and a mere change of opinion is not legally sustainable; the reassessment notice and resulting order were quashed in favour of the assessee. Case-Laws Income Tax Wed, 29 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790896