https://www.taxtmi.com/caselaws?id=793556 Reassessment after four years from the end of the assessment year cannot be sustained unless the Revenue shows a specific failure by the assessee to disclose fully and truly all material facts. Here, the return, audit material, annual report and scrutiny proceedings already disclosed the business structure, licence arrangement and transfer pricing details, so reopening was based only on reappraisal of the same material and was invalid. The recorded reasons were also unsustainable on the deduction issue because section 80-IA(4) was misapplied on ownership and new infrastructure facility: the Indian port undertaking, not a Mauritius entity, was the relevant enterprise, and the reasons ignored the terminal development, equipment and earlier accepted assessments. The notice and related orders were quashed. en-us Tue, 16 Jun 2026 00:00:00 +0530 Thu, 18 Jun 2026 08:45:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793556 Reassessment after four years from the end of the assessment year cannot be sustained unless the Revenue shows a specific failure by the assessee to disclose fully and truly all material facts. Here, the return, audit material, annual report and scrutiny proceedings already disclosed the business structure, licence arrangement and transfer pricing details, so reopening was based only on reappraisal of the same material and was invalid. The recorded reasons were also unsustainable on the deduction issue because section 80-IA(4) was misapplied on ownership and new infrastructure facility: the Indian port undertaking, not a Mauritius entity, was the relevant enterprise, and the reasons ignored the terminal development, equipment and earlier accepted assessments. The notice and related orders were quashed. Case-Laws Income Tax Tue, 16 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793556