https://www.taxtmi.com/caselaws?id=800591 The first proviso to Section 147 restricts reassessment initiated after four years from the end of the relevant assessment year where the original assessment was completed under Section 143(3). Reopening is permissible only where escaped income resulted from the assessee's failure to fully and truly disclose all material facts. Disclosure of complete share-sale transaction particulars during the original scrutiny assessment, coupled with recorded reasons that do not allege such failure, does not satisfy the statutory condition for reopening beyond four years. en-us Mon, 28 Sep 2026 00:00:00 +0530 Thu, 08 Oct 2026 08:45:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800591 The first proviso to Section 147 restricts reassessment initiated after four years from the end of the relevant assessment year where the original assessment was completed under Section 143(3). Reopening is permissible only where escaped income resulted from the assessee's failure to fully and truly disclose all material facts. Disclosure of complete share-sale transaction particulars during the original scrutiny assessment, coupled with recorded reasons that do not allege such failure, does not satisfy the statutory condition for reopening beyond four years. Case-Laws Income Tax Mon, 28 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800591