https://www.taxtmi.com/caselaws?id=792287 Reassessment under section 147 is not valid where the material relied upon was already available during the original assessment and the recorded reasons do not establish failure to disclose fully and truly all material facts. On those facts, reopening based on Form 26AS and TCS information was unsustainable. An addition under section 69 for excess purchase cannot be made where the reassessment was initiated for a different issue, because the impugned addition must be linked to the recorded reasons for reopening. The amount was also stated to have been accounted for in the subsequent year, which raised the risk of double addition. The reassessment and the addition were both set aside. en-us Thu, 21 May 2026 00:00:00 +0530 Tue, 26 May 2026 08:24:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792287 Reassessment under section 147 is not valid where the material relied upon was already available during the original assessment and the recorded reasons do not establish failure to disclose fully and truly all material facts. On those facts, reopening based on Form 26AS and TCS information was unsustainable. An addition under section 69 for excess purchase cannot be made where the reassessment was initiated for a different issue, because the impugned addition must be linked to the recorded reasons for reopening. The amount was also stated to have been accounted for in the subsequent year, which raised the risk of double addition. The reassessment and the addition were both set aside. Case-Laws Income Tax Thu, 21 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792287