https://www.taxtmi.com/caselaws?id=797170 Reassessment initiated beyond four years requires established failure by the assessee to make a full and true disclosure regarding the income alleged to have escaped assessment on the recorded reasons. Where no addition survives on either recorded ground-recomputation of Section 14A disallowance or alleged NSEL income-an addition on a separate issue lacks jurisdictional support. Explanation 3 to Section 147 permits assessment of another escaped-income issue discovered during valid reassessment proceedings, but does not cure an invalid reopening or enlarge the substantive jurisdiction under Section 147. The reassessment and the unrelated addition could not survive. en-us Tue, 04 Aug 2026 00:00:00 +0530 Tue, 18 Aug 2026 08:35:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797170 Reassessment initiated beyond four years requires established failure by the assessee to make a full and true disclosure regarding the income alleged to have escaped assessment on the recorded reasons. Where no addition survives on either recorded ground-recomputation of Section 14A disallowance or alleged NSEL income-an addition on a separate issue lacks jurisdictional support. Explanation 3 to Section 147 permits assessment of another escaped-income issue discovered during valid reassessment proceedings, but does not cure an invalid reopening or enlarge the substantive jurisdiction under Section 147. The reassessment and the unrelated addition could not survive. Case-Laws Income Tax Tue, 04 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797170