https://www.taxtmi.com/caselaws?id=794538 Reopening of a scrutiny assessment completed under section 143(3) after four years is valid only if the recorded reasons specifically show that escapement of income resulted from the assessee's failure to disclose fully and truly all material facts necessary for assessment. Here, the reasons for reopening did not contain that jurisdictional allegation, and the material relied on was already available during the original assessment. The first proviso to section 147 was therefore not satisfied, so the reassessment notice and consequential reassessment order were quashed. en-us Wed, 01 Jul 2026 00:00:00 +0530 Tue, 07 Jul 2026 08:39:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794538 Reopening of a scrutiny assessment completed under section 143(3) after four years is valid only if the recorded reasons specifically show that escapement of income resulted from the assessee's failure to disclose fully and truly all material facts necessary for assessment. Here, the reasons for reopening did not contain that jurisdictional allegation, and the material relied on was already available during the original assessment. The first proviso to section 147 was therefore not satisfied, so the reassessment notice and consequential reassessment order were quashed. Case-Laws Income Tax Wed, 01 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794538