https://www.taxtmi.com/caselaws?id=794250 Reassessment beyond four years was held impermissible where the original scrutiny assessment under section 143(3) had already examined the deduction claim and the Revenue relied on the same material without any fresh tangible material. The proviso to section 147 was not satisfied because there was no demonstrated failure by the assessee to fully and truly disclose material facts, so the reopening was treated as a change of opinion. The perfunctory rejection of objections was also unsustainable, and the reassessment notice and objection order were quashed. en-us Mon, 22 Jun 2026 00:00:00 +0530 Thu, 02 Jul 2026 08:07:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794250 Reassessment beyond four years was held impermissible where the original scrutiny assessment under section 143(3) had already examined the deduction claim and the Revenue relied on the same material without any fresh tangible material. The proviso to section 147 was not satisfied because there was no demonstrated failure by the assessee to fully and truly disclose material facts, so the reopening was treated as a change of opinion. The perfunctory rejection of objections was also unsustainable, and the reassessment notice and objection order were quashed. Case-Laws Income Tax Mon, 22 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794250