https://www.taxtmi.com/caselaws?id=469756 Reassessment under section 147 was invalid where the recorded reasons wrongly assumed that no return had been filed and that there was no response to the section 133(6) notice, although the return had in fact been filed, assessed under section 143(3), and the assessee had replied to the enquiry. Because the reopening was initiated beyond four years from the end of the assessment year after a completed section 143(3) assessment, the proviso to section 147 required a recorded satisfaction that escapement arose from failure to disclose fully and truly all material facts. No such satisfaction appeared in the reasons, and it could not be supplied later. The section 148 notice was therefore without jurisdiction and was set aside. en-us Tue, 26 Nov 2024 00:00:00 +0530 Thu, 02 Jul 2026 20:38:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469756 Reassessment under section 147 was invalid where the recorded reasons wrongly assumed that no return had been filed and that there was no response to the section 133(6) notice, although the return had in fact been filed, assessed under section 143(3), and the assessee had replied to the enquiry. Because the reopening was initiated beyond four years from the end of the assessment year after a completed section 143(3) assessment, the proviso to section 147 required a recorded satisfaction that escapement arose from failure to disclose fully and truly all material facts. No such satisfaction appeared in the reasons, and it could not be supplied later. The section 148 notice was therefore without jurisdiction and was set aside. Case-Laws Income Tax Tue, 26 Nov 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469756