https://www.taxtmi.com/caselaws?id=794605 Beyond four years, reassessment under section 148 failed because it rested on the same material already examined, with no tangible new material and no recorded failure by the assessee to disclose fully and truly all material facts; the reopening was treated as a change of opinion and borrowed satisfaction, so the notice was without jurisdiction. The section 68 addition on share capital and share premium also failed because the assessee produced subscriber-wise documentary evidence, including PAN, bank records, returns and financial statements, and the subscribers had responded to earlier notices. As the Assessing Officer brought no cogent adverse material or further enquiry to rebut that evidence, the initial onus was discharged and the addition was deleted. en-us Thu, 25 Jun 2026 00:00:00 +0530 Wed, 08 Jul 2026 09:08:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794605 Beyond four years, reassessment under section 148 failed because it rested on the same material already examined, with no tangible new material and no recorded failure by the assessee to disclose fully and truly all material facts; the reopening was treated as a change of opinion and borrowed satisfaction, so the notice was without jurisdiction. The section 68 addition on share capital and share premium also failed because the assessee produced subscriber-wise documentary evidence, including PAN, bank records, returns and financial statements, and the subscribers had responded to earlier notices. As the Assessing Officer brought no cogent adverse material or further enquiry to rebut that evidence, the initial onus was discharged and the addition was deleted. Case-Laws Income Tax Thu, 25 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794605