https://www.taxtmi.com/caselaws?id=798212 Reassessment initiated after four years is jurisdictionally invalid where the capital-gain transaction was fully disclosed, examined in the original assessment, and reopening rests on no fresh tangible material or identified failure of full and true disclosure. Reconsidering the same transaction constitutes a change of opinion. Reassessment is also invalid where a return filed in response to a section 148 notice is followed by no notice under section 143(2). Issuance of that notice is mandatory after receipt of the return; treating the return as non est or relying on delayed filing does not cure its omission. The reassessment order and consequential addition therefore cannot survive. en-us Mon, 31 Aug 2026 00:00:00 +0530 Thu, 03 Sep 2026 08:20:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798212 Reassessment initiated after four years is jurisdictionally invalid where the capital-gain transaction was fully disclosed, examined in the original assessment, and reopening rests on no fresh tangible material or identified failure of full and true disclosure. Reconsidering the same transaction constitutes a change of opinion. Reassessment is also invalid where a return filed in response to a section 148 notice is followed by no notice under section 143(2). Issuance of that notice is mandatory after receipt of the return; treating the return as non est or relying on delayed filing does not cure its omission. The reassessment order and consequential addition therefore cannot survive. Case-Laws Income Tax Mon, 31 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798212