https://www.taxtmi.com/caselaws?id=795338 Reassessment initiated after four years from the relevant assessment year requires recorded reasons based on tangible material indicating escaped income and must disclose the assessee's failure to make a full and true disclosure of material facts. Revisiting software expenditure already examined in the original scrutiny assessment, without fresh material or an identified disclosure failure, constitutes an impermissible change of opinion rather than a valid basis for reopening. Where the assessee had furnished the requested software-expense details and ledger during the original assessment, a proposal to capitalise that expenditure cannot support reassessment jurisdiction. en-us Mon, 22 Jun 2026 00:00:00 +0530 Tue, 21 Jul 2026 08:32:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795338 Reassessment initiated after four years from the relevant assessment year requires recorded reasons based on tangible material indicating escaped income and must disclose the assessee's failure to make a full and true disclosure of material facts. Revisiting software expenditure already examined in the original scrutiny assessment, without fresh material or an identified disclosure failure, constitutes an impermissible change of opinion rather than a valid basis for reopening. Where the assessee had furnished the requested software-expense details and ledger during the original assessment, a proposal to capitalise that expenditure cannot support reassessment jurisdiction. Case-Laws Income Tax Mon, 22 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795338