https://www.taxtmi.com/caselaws?id=469488 Reopening of an assessment beyond four years under the Income-tax Act was unsustainable where the original assessment was completed under Section 143(3), the assessee had disclosed all material facts during scrutiny, and no fresh tangible material supported the alleged reasons to believe. A reopening based only on re-verification of the same claim amounted to a mere change of opinion, which cannot justify action under Section 147. Because the statutory proviso for reopening after four years requires a failure to fully and truly disclose material facts, and that threshold was not met, the reassessment notice and the order rejecting objections were quashed. en-us Thu, 06 Feb 2025 00:00:00 +0530 Thu, 18 Jun 2026 18:59:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469488 Reopening of an assessment beyond four years under the Income-tax Act was unsustainable where the original assessment was completed under Section 143(3), the assessee had disclosed all material facts during scrutiny, and no fresh tangible material supported the alleged reasons to believe. A reopening based only on re-verification of the same claim amounted to a mere change of opinion, which cannot justify action under Section 147. Because the statutory proviso for reopening after four years requires a failure to fully and truly disclose material facts, and that threshold was not met, the reassessment notice and the order rejecting objections were quashed. Case-Laws Income Tax Thu, 06 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469488