https://www.taxtmi.com/caselaws?id=470053 Reassessment initiated after four years from the relevant assessment year requires a recorded failure by the assessee to disclose fully and truly all material facts where the original assessment was completed under scrutiny. Reopening lacked jurisdiction because the recorded reasons incorrectly asserted that no scrutiny assessment had occurred and alleged undisclosed penny-stock accommodation entries despite no claimed related capital gains or losses and prior disclosure of relevant details. In the absence of the statutory condition under the first proviso to Section 147, notices issued under Section 148 and resulting reassessments were 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 initiated after four years from the relevant assessment year requires a recorded failure by the assessee to disclose fully and truly all material facts where the original assessment was completed under scrutiny. Reopening lacked jurisdiction because the recorded reasons incorrectly asserted that no scrutiny assessment had occurred and alleged undisclosed penny-stock accommodation entries despite no claimed related capital gains or losses and prior disclosure of relevant details. In the absence of the statutory condition under the first proviso to Section 147, notices issued under Section 148 and resulting reassessments were quashed. Case-Laws Income Tax Wed, 12 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470053