https://www.taxtmi.com/caselaws?id=471691 Reassessment initiated beyond four years is invalid where share application money was specifically examined, verified through confirmations and books of account, and accepted in the original scrutiny assessment. Reopening on the same material constitutes a change of opinion unless recorded reasons identify fresh information and establish the assessee's failure to disclose fully and truly all material facts. As neither condition was met, the reassessment notice and consequential reopening were unsustainable and quashed. en-us Wed, 09 Apr 2025 00:00:00 +0530 Mon, 14 Sep 2026 19:03:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471691 Reassessment initiated beyond four years is invalid where share application money was specifically examined, verified through confirmations and books of account, and accepted in the original scrutiny assessment. Reopening on the same material constitutes a change of opinion unless recorded reasons identify fresh information and establish the assessee's failure to disclose fully and truly all material facts. As neither condition was met, the reassessment notice and consequential reopening were unsustainable and quashed. Case-Laws Income Tax Wed, 09 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471691