https://www.taxtmi.com/caselaws?id=791797 Reopening beyond four years after scrutiny assessment under section 143(3) was barred because the recorded reasons relied on the same material already examined in the original assessment. The issue of alleged bogus or accommodation purchases had been specifically called for, disclosed, and considered during the regular assessment, and no new tangible material or independent investigation emerged later. In the absence of any failure by the assessee to fully and truly disclose material facts, the first proviso to section 147 applied and the reassessment amounted to a mere change of opinion. The reassessment was therefore held invalid and quashed. en-us Mon, 11 May 2026 00:00:00 +0530 Mon, 18 May 2026 08:40:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791797 Reopening beyond four years after scrutiny assessment under section 143(3) was barred because the recorded reasons relied on the same material already examined in the original assessment. The issue of alleged bogus or accommodation purchases had been specifically called for, disclosed, and considered during the regular assessment, and no new tangible material or independent investigation emerged later. In the absence of any failure by the assessee to fully and truly disclose material facts, the first proviso to section 147 applied and the reassessment amounted to a mere change of opinion. The reassessment was therefore held invalid and quashed. Case-Laws Income Tax Mon, 11 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791797