https://www.taxtmi.com/caselaws?id=794684 Reopening of an assessment beyond four years under section 148 of the Income-tax Act is not sustainable where the original assessment under section 143(3) had already examined the very expenses in issue and the recorded reasons rely only on material already on record. In the absence of fresh tangible material, and where no failure to fully and truly disclose material facts was shown, the reopening amounts to a mere change of opinion. On that basis, the notice for reassessment and the consequential proceedings were quashed in favour of the assessee. en-us Mon, 06 Jul 2026 00:00:00 +0530 Thu, 09 Jul 2026 08:35:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794684 Reopening of an assessment beyond four years under section 148 of the Income-tax Act is not sustainable where the original assessment under section 143(3) had already examined the very expenses in issue and the recorded reasons rely only on material already on record. In the absence of fresh tangible material, and where no failure to fully and truly disclose material facts was shown, the reopening amounts to a mere change of opinion. On that basis, the notice for reassessment and the consequential proceedings were quashed in favour of the assessee. Case-Laws Income Tax Mon, 06 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794684