https://www.taxtmi.com/caselaws?id=792893 Reopening beyond four years under the Income-tax Act, 1961 requires the recorded reasons to expressly show the assessee's failure to fully and truly disclose all material facts necessary for assessment. Where the original assessments were completed under section 143(3) and the section 148 notices were issued after four years, absence of that jurisdictional assertion in the recorded reasons rendered reopening invalid. The defect was compounded because the reopening was based on an incorrect factual premise that no return had been filed and no scrutiny assessment existed, although the record showed otherwise. The reassessment proceedings were quashed for both years. en-us Fri, 15 May 2026 00:00:00 +0530 Fri, 05 Jun 2026 08:07:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792893 Reopening beyond four years under the Income-tax Act, 1961 requires the recorded reasons to expressly show the assessee's failure to fully and truly disclose all material facts necessary for assessment. Where the original assessments were completed under section 143(3) and the section 148 notices were issued after four years, absence of that jurisdictional assertion in the recorded reasons rendered reopening invalid. The defect was compounded because the reopening was based on an incorrect factual premise that no return had been filed and no scrutiny assessment existed, although the record showed otherwise. The reassessment proceedings were quashed for both years. Case-Laws Income Tax Fri, 15 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792893