https://www.taxtmi.com/caselaws?id=471388 Reassessment initiated more than four years after an assessment under Section 143(3) requires the recorded reasons to establish the assessee's failure to make a full and true disclosure of all material facts necessary for assessment. Where the recorded reasons contain no such allegation, the statutory jurisdictional condition under the first proviso to Section 147 is not met. The reasons must independently demonstrate this condition and cannot be supplemented or improved later. Reassessment proceedings commenced without this recorded allegation are invalid and liable to be quashed. en-us Wed, 12 Feb 2025 00:00:00 +0530 Tue, 01 Sep 2026 19:02:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471388 Reassessment initiated more than four years after an assessment under Section 143(3) requires the recorded reasons to establish the assessee's failure to make a full and true disclosure of all material facts necessary for assessment. Where the recorded reasons contain no such allegation, the statutory jurisdictional condition under the first proviso to Section 147 is not met. The reasons must independently demonstrate this condition and cannot be supplemented or improved later. Reassessment proceedings commenced without this recorded allegation are invalid and liable to be quashed. Case-Laws Income Tax Wed, 12 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471388