https://www.taxtmi.com/caselaws?id=792146 Reassessment initiated beyond four years from the end of the assessment year was held invalid because the recorded reasons relied on material already examined in the original scrutiny assessment. The assessee had disclosed the relevant facts concerning sale of development rights, consideration received, fixed deposits and the exemption claim before the section 143(3) assessment. In the absence of any new tangible material or any demonstrated failure by the assessee to fully and truly disclose material facts, the proviso to section 147 was not satisfied. The reopening was therefore treated as a mere change of opinion and was invalid. en-us Wed, 29 Apr 2026 00:00:00 +0530 Sat, 23 May 2026 08:27:15 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792146 Reassessment initiated beyond four years from the end of the assessment year was held invalid because the recorded reasons relied on material already examined in the original scrutiny assessment. The assessee had disclosed the relevant facts concerning sale of development rights, consideration received, fixed deposits and the exemption claim before the section 143(3) assessment. In the absence of any new tangible material or any demonstrated failure by the assessee to fully and truly disclose material facts, the proviso to section 147 was not satisfied. The reopening was therefore treated as a mere change of opinion and was invalid. Case-Laws Income Tax Wed, 29 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792146