Reassessment Beyond Four Years Allowed Only if Taxpayer Fails Full Disclosure; Change of Opinion Not Valid Ground.

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....Reopening of assessment - reason to believe - onus to prove - The High court noted that reassessment beyond four years from the end of the relevant assessment year is permissible only if there is a failure by the taxpayer to disclose fully and truly all material facts necessary for assessment. - The court observed that the petitioner had disclosed all primary facts related to the waiver of loans in the original assessment proceedings. It was emphasized that the production of account books or other evidence does not necessarily amount to full disclosure as required by law. - As such, the reassessment was deemed to be based on a change of opinion, which is not a valid ground for reopening an assessment under the relevant sections of the Act.....