https://www.taxtmi.com/caselaws?id=794152 Reassessment beyond four years under section 147 requires the Revenue to show failure by the assessee to disclose fully and truly all material facts; a mere reappraisal of material already on record amounts to change of opinion and cannot sustain jurisdiction. On that basis, the reopening was held invalid and the notice under section 148 was quashed. A disallowance under section 37(1) for alleged prohibited sub-brokerage under SEBI regulations also failed because the record did not establish that the recipients acted as sub-brokers or that any statutory contravention occurred. The expenditure was therefore not treated as prohibited, and the disallowance was deleted. en-us Thu, 25 Jun 2026 00:00:00 +0530 Wed, 01 Jul 2026 08:47:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794152 Reassessment beyond four years under section 147 requires the Revenue to show failure by the assessee to disclose fully and truly all material facts; a mere reappraisal of material already on record amounts to change of opinion and cannot sustain jurisdiction. On that basis, the reopening was held invalid and the notice under section 148 was quashed. A disallowance under section 37(1) for alleged prohibited sub-brokerage under SEBI regulations also failed because the record did not establish that the recipients acted as sub-brokers or that any statutory contravention occurred. The expenditure was therefore not treated as prohibited, and the disallowance was deleted. Case-Laws Income Tax Thu, 25 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794152