https://www.taxtmi.com/caselaws?id=799316 Reassessment after a completed scrutiny assessment cannot revisit the existence of a permanent establishment where the issue was specifically examined, the taxpayer furnished detailed replies, and reopening relies on the same material. The absence of an express finding in the assessment order does not permit correction of an Assessing Officer's omission; such reopening constitutes a change of opinion and undermines assessment finality. Beyond four years, reassessment requires income escapement caused by failure to make full and true disclosure. Where subscription receipts and the Indian agent's role were disclosed during scrutiny, that condition is absent, and a notice issued after the applicable limitation period is time-barred. en-us Thu, 10 Sep 2026 00:00:00 +0530 Sat, 19 Sep 2026 08:20:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799316 Reassessment after a completed scrutiny assessment cannot revisit the existence of a permanent establishment where the issue was specifically examined, the taxpayer furnished detailed replies, and reopening relies on the same material. The absence of an express finding in the assessment order does not permit correction of an Assessing Officer's omission; such reopening constitutes a change of opinion and undermines assessment finality. Beyond four years, reassessment requires income escapement caused by failure to make full and true disclosure. Where subscription receipts and the Indian agent's role were disclosed during scrutiny, that condition is absent, and a notice issued after the applicable limitation period is time-barred. Case-Laws Income Tax Thu, 10 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799316