https://www.taxtmi.com/caselaws?id=799212 Reassessment beyond four years after a completed scrutiny assessment requires the additional jurisdictional condition under the first proviso to Section 147: failure by the assessee to disclose fully and truly all material facts necessary for assessment. Later information suggesting income escapement is insufficient unless the recorded reasons identify a withheld primary fact and link that failure to the alleged escapement. Where transactions were disclosed during original scrutiny, jurisdiction must stand or fail solely on contemporaneously recorded reasons; later supplementation cannot cure defects. The Section 148 notice and reassessment were quashed for want of jurisdiction. en-us Fri, 21 Aug 2026 00:00:00 +0530 Fri, 18 Sep 2026 07:32:03 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799212 Reassessment beyond four years after a completed scrutiny assessment requires the additional jurisdictional condition under the first proviso to Section 147: failure by the assessee to disclose fully and truly all material facts necessary for assessment. Later information suggesting income escapement is insufficient unless the recorded reasons identify a withheld primary fact and link that failure to the alleged escapement. Where transactions were disclosed during original scrutiny, jurisdiction must stand or fail solely on contemporaneously recorded reasons; later supplementation cannot cure defects. The Section 148 notice and reassessment were quashed for want of jurisdiction. Case-Laws Income Tax Fri, 21 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799212