https://www.taxtmi.com/caselaws?id=470053 Reassessment after four years from the relevant assessment year requires, under the first proviso to Section 147 of the Income-tax Act, 1961, a failure by the assessee to disclose fully and truly all material facts necessary for assessment. The article notes that original assessments had been completed under Section 143(3), while the recorded reasons incorrectly stated that no scrutiny assessments had occurred and alleged undisclosed penny-stock accommodation entries that were neither claimed nor omitted from the details furnished. As no failure of disclosure was recorded, the jurisdictional condition for reopening was not satisfied. The reassessment notices under Section 148 and consequential assessments under Section 147 were therefore described as without jurisdiction and quashed. en-us Wed, 12 Mar 2025 00:00:00 +0530 Tue, 14 Jul 2026 19:02:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470053 Reassessment after four years from the relevant assessment year requires, under the first proviso to Section 147 of the Income-tax Act, 1961, a failure by the assessee to disclose fully and truly all material facts necessary for assessment. The article notes that original assessments had been completed under Section 143(3), while the recorded reasons incorrectly stated that no scrutiny assessments had occurred and alleged undisclosed penny-stock accommodation entries that were neither claimed nor omitted from the details furnished. As no failure of disclosure was recorded, the jurisdictional condition for reopening was not satisfied. The reassessment notices under Section 148 and consequential assessments under Section 147 were therefore described as without jurisdiction and quashed. Case-Laws Income Tax Wed, 12 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470053