https://www.taxtmi.com/caselaws?id=801409 Reassessment initiated more than four years after a completed scrutiny assessment requires the taxpayer's failure to file a return or to make full and true disclosure of material facts. Where a discrepancy between TDS-certificate receipts and profit-and-loss-account receipts was specifically queried and answered during the original assessment, no failure of disclosure arises. Reopening solely through reappraisal of already examined material, without fresh tangible material, constitutes an impermissible change of opinion and lacks statutory jurisdiction. en-us Wed, 07 Oct 2026 00:00:00 +0530 Wed, 21 Oct 2026 08:37:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=801409 Reassessment initiated more than four years after a completed scrutiny assessment requires the taxpayer's failure to file a return or to make full and true disclosure of material facts. Where a discrepancy between TDS-certificate receipts and profit-and-loss-account receipts was specifically queried and answered during the original assessment, no failure of disclosure arises. Reopening solely through reappraisal of already examined material, without fresh tangible material, constitutes an impermissible change of opinion and lacks statutory jurisdiction. Case-Laws Income Tax Wed, 07 Oct 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=801409