https://www.taxtmi.com/caselaws?id=471134 Reassessment beyond four years is invalid where deduction-related scrap sales and job-work receipts were specifically examined in the original scrutiny assessment and no failure to disclose fully and truly all material facts is established. The proviso to Section 147 requires such disclosure failure for reopening after four years. Reliance solely on the existing assessment record, without tangible material indicating escaped income, amounts to an impermissible change of opinion. The reassessment was therefore quashed for lack of jurisdiction. en-us Wed, 02 Apr 2025 00:00:00 +0530 Fri, 21 Aug 2026 20:33:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471134 Reassessment beyond four years is invalid where deduction-related scrap sales and job-work receipts were specifically examined in the original scrutiny assessment and no failure to disclose fully and truly all material facts is established. The proviso to Section 147 requires such disclosure failure for reopening after four years. Reliance solely on the existing assessment record, without tangible material indicating escaped income, amounts to an impermissible change of opinion. The reassessment was therefore quashed for lack of jurisdiction. Case-Laws Income Tax Wed, 02 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471134