https://www.taxtmi.com/caselaws?id=791689 A completed scrutiny assessment under section 143(3) cannot be reopened beyond four years on the basis of the same material already examined in the original assessment unless the Assessing Officer records a specific failure by the assessee to disclose fully and truly all material facts. Here, the reasons for reopening under section 148 relied only on the existing assessment record and no independent tangible material or disclosure failure was shown. The first proviso to section 147 therefore barred the reassessment, and the reopening was treated as an impermissible change of opinion and an attempt to review a concluded assessment. The reassessment proceedings were quashed in favour of the assessee. en-us Fri, 17 Apr 2026 00:00:00 +0530 Fri, 15 May 2026 09:15:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791689 A completed scrutiny assessment under section 143(3) cannot be reopened beyond four years on the basis of the same material already examined in the original assessment unless the Assessing Officer records a specific failure by the assessee to disclose fully and truly all material facts. Here, the reasons for reopening under section 148 relied only on the existing assessment record and no independent tangible material or disclosure failure was shown. The first proviso to section 147 therefore barred the reassessment, and the reopening was treated as an impermissible change of opinion and an attempt to review a concluded assessment. The reassessment proceedings were quashed in favour of the assessee. Case-Laws Income Tax Fri, 17 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791689