https://www.taxtmi.com/caselaws?id=470997 Reassessment initiated more than four years after the relevant assessment year, following an original assessment under Section 143(3), requires recorded reasons showing that income escaped assessment because of the assessee's failure to disclose fully and truly all material facts. Alleged information regarding accommodation entries does not remove that jurisdictional requirement. Where the recorded reasons neither identify nor allege such disclosure failure, reassessment is invalid for non-compliance with the first proviso to Section 147. en-us Fri, 28 Mar 2025 00:00:00 +0530 Mon, 17 Aug 2026 22:08:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=470997 Reassessment initiated more than four years after the relevant assessment year, following an original assessment under Section 143(3), requires recorded reasons showing that income escaped assessment because of the assessee's failure to disclose fully and truly all material facts. Alleged information regarding accommodation entries does not remove that jurisdictional requirement. Where the recorded reasons neither identify nor allege such disclosure failure, reassessment is invalid for non-compliance with the first proviso to Section 147. Case-Laws Income Tax Fri, 28 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=470997