https://www.taxtmi.com/caselaws?id=469941 Reassessment initiated after four years from the end of the relevant assessment year is valid only if the recorded reasons expressly allege that the assessee failed to disclose fully and truly all material facts necessary for assessment. Where the original assessment was completed under section 143(3) and the section 148 notice was issued beyond four years, the absence of that jurisdictional allegation in the recorded reasons is fatal to reopening. The reassessment initiation was therefore invalid and quashed. en-us Wed, 12 Mar 2025 00:00:00 +0530 Thu, 09 Jul 2026 20:20:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469941 Reassessment initiated after four years from the end of the relevant assessment year is valid only if the recorded reasons expressly allege that the assessee failed to disclose fully and truly all material facts necessary for assessment. Where the original assessment was completed under section 143(3) and the section 148 notice was issued beyond four years, the absence of that jurisdictional allegation in the recorded reasons is fatal to reopening. The reassessment initiation was therefore invalid and quashed. Case-Laws Income Tax Wed, 12 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469941