https://www.taxtmi.com/caselaws?id=793951 Reassessment beyond four years under section 147 requires the recorded reasons to show failure by the assessee to fully and truly disclose material facts; absent that condition, reopening is invalid. The recorded reasons here did not allege any such failure, and the recruitment and training expense material had already been disclosed in the audited financial statements, return, and original assessment record under section 143(3). No new tangible material or external information supported the reopening, so the action rested only on re-examination of the same material. The reassessment was therefore without jurisdiction as a mere change of opinion. en-us Wed, 24 Jun 2026 00:00:00 +0530 Fri, 26 Jun 2026 07:07:32 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793951 Reassessment beyond four years under section 147 requires the recorded reasons to show failure by the assessee to fully and truly disclose material facts; absent that condition, reopening is invalid. The recorded reasons here did not allege any such failure, and the recruitment and training expense material had already been disclosed in the audited financial statements, return, and original assessment record under section 143(3). No new tangible material or external information supported the reopening, so the action rested only on re-examination of the same material. The reassessment was therefore without jurisdiction as a mere change of opinion. Case-Laws Income Tax Wed, 24 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793951