https://www.taxtmi.com/caselaws?id=802486 Reopening an assessment beyond four years after a scrutiny assessment requires the recorded reasons to identify the assessee's failure to disclose fully and truly all material facts necessary for assessment. Those reasons cannot be supplemented subsequently. Where share application money was examined and applicant details and PANs were supplied during the original assessment, reasons based on inquiries for a later year cannot support reopening without identifying a disclosure failure for the relevant year. Without that disclosure failure, the reopening notice lacks jurisdiction. en-us Mon, 26 Oct 2026 00:00:00 +0530 Fri, 06 Nov 2026 08:29:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=802486 Reopening an assessment beyond four years after a scrutiny assessment requires the recorded reasons to identify the assessee's failure to disclose fully and truly all material facts necessary for assessment. Those reasons cannot be supplemented subsequently. Where share application money was examined and applicant details and PANs were supplied during the original assessment, reasons based on inquiries for a later year cannot support reopening without identifying a disclosure failure for the relevant year. Without that disclosure failure, the reopening notice lacks jurisdiction. Case-Laws Income Tax Mon, 26 Oct 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=802486