https://www.taxtmi.com/caselaws?id=469908 Reassessment notice issued after four years from the end of the relevant assessment year was held invalid where the original assessment had been completed under section 143(3) and the recorded reasons did not allege any failure by the assessee to fully and truly disclose all material facts necessary for assessment. The first proviso to section 147 operates as a jurisdictional bar in such cases, so mere reference to investigation material or a need for further inquiry is insufficient. The reopening was quashed and the assessee succeeded on the jurisdictional challenge. en-us Tue, 11 Mar 2025 00:00:00 +0530 Wed, 08 Jul 2026 20:43:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469908 Reassessment notice issued after four years from the end of the relevant assessment year was held invalid where the original assessment had been completed under section 143(3) and the recorded reasons did not allege any failure by the assessee to fully and truly disclose all material facts necessary for assessment. The first proviso to section 147 operates as a jurisdictional bar in such cases, so mere reference to investigation material or a need for further inquiry is insufficient. The reopening was quashed and the assessee succeeded on the jurisdictional challenge. Case-Laws Income Tax Tue, 11 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469908