https://www.taxtmi.com/caselaws?id=472575 Reassessment initiated beyond four years requires both a reason to believe that income escaped assessment and the assessee's failure to make full and true disclosure of material facts. Where foreign-exchange loss, additional depreciation and interest income were examined during the original scrutiny assessment and supported by records, acceptance of the claims establishes an opinion even without express discussion in the assessment order. Absent new material or a disclosure failure, reopening is an impermissible change of opinion; recorded reasons cannot be supplemented by an unrecorded audit objection, rendering the reopening jurisdictionally invalid. en-us Wed, 09 Oct 2024 00:00:00 +0530 Fri, 16 Oct 2026 14:43:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=472575 Reassessment initiated beyond four years requires both a reason to believe that income escaped assessment and the assessee's failure to make full and true disclosure of material facts. Where foreign-exchange loss, additional depreciation and interest income were examined during the original scrutiny assessment and supported by records, acceptance of the claims establishes an opinion even without express discussion in the assessment order. Absent new material or a disclosure failure, reopening is an impermissible change of opinion; recorded reasons cannot be supplemented by an unrecorded audit objection, rendering the reopening jurisdictionally invalid. Case-Laws Income Tax Wed, 09 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=472575