https://www.taxtmi.com/caselaws?id=471892 Extended-period reopening of a completed scrutiny assessment under the first proviso to Section 147 requires recorded reasons to identify the assessee's failure to make a full and true disclosure of material facts. Recorded reasons cannot be supplemented later to establish that jurisdictional condition. Where fixed-asset additions, capitalised exchange fluctuation, relevant equipment and additional depreciation were fully furnished and examined during original scrutiny, a later reconsideration of the depreciation statement without alleging withheld facts does not satisfy the statutory condition. The reassessment proceedings and consequent order are ab initio void. en-us Tue, 29 Jul 2025 00:00:00 +0530 Tue, 22 Sep 2026 13:47:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471892 Extended-period reopening of a completed scrutiny assessment under the first proviso to Section 147 requires recorded reasons to identify the assessee's failure to make a full and true disclosure of material facts. Recorded reasons cannot be supplemented later to establish that jurisdictional condition. Where fixed-asset additions, capitalised exchange fluctuation, relevant equipment and additional depreciation were fully furnished and examined during original scrutiny, a later reconsideration of the depreciation statement without alleging withheld facts does not satisfy the statutory condition. The reassessment proceedings and consequent order are ab initio void. Case-Laws Income Tax Tue, 29 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471892