https://www.taxtmi.com/caselaws?id=792421 Reassessment reopening is invalid where the recorded reasons do not allege that the assessee failed to disclose fully and truly all material facts necessary for assessment. The ITAT Delhi found that the reopening reasons contained no such allegation and therefore lacked the jurisdictional foundation required to invoke reassessment. Once that defect was established, the merits of the addition became academic. The reopening was quashed and the reassessment challenge succeeded. en-us Wed, 29 Apr 2026 00:00:00 +0530 Thu, 28 May 2026 08:21:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792421 Reassessment reopening is invalid where the recorded reasons do not allege that the assessee failed to disclose fully and truly all material facts necessary for assessment. The ITAT Delhi found that the reopening reasons contained no such allegation and therefore lacked the jurisdictional foundation required to invoke reassessment. Once that defect was established, the merits of the addition became academic. The reopening was quashed and the reassessment challenge succeeded. Case-Laws Income Tax Wed, 29 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792421