https://www.taxtmi.com/caselaws?id=795338 Reassessment initiated after four years requires recorded reasons based on tangible material and disclosure of the assessee's failure to fully and truly disclose material facts. Where software expenditure and supporting ledger details were specifically sought and furnished during the original scrutiny assessment, revisiting the profit and loss account to propose capitalisation, without fresh material or an alleged disclosure failure, amounts to an impermissible change of opinion. The notes state that the Section 148 notice and consequential reassessment were without jurisdiction, void from inception, and quashed. 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 requires recorded reasons based on tangible material and disclosure of the assessee's failure to fully and truly disclose material facts. Where software expenditure and supporting ledger details were specifically sought and furnished during the original scrutiny assessment, revisiting the profit and loss account to propose capitalisation, without fresh material or an alleged disclosure failure, amounts to an impermissible change of opinion. The notes state that the Section 148 notice and consequential reassessment were without jurisdiction, void from inception, and quashed. Case-Laws Income Tax Mon, 22 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795338