Reopening beyond the statutory time limit fails when recorded reasons lack tangible material and disclosures were complete.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Reopening of a concluded scrutiny assessment beyond four years requires recorded reasons that independently demonstrate tangible material, a rational link to income escaping assessment, and the taxpayer's failure to make a full and true disclosure of primary facts. Recorded reasons containing factual errors and no connection between an alleged entry operator and the shareholder do not establish due application of mind or a valid reason to believe. Disclosure of shareholder details, banking particulars and confirmations satisfies the taxpayer's obligation; the taxpayer need not draw further factual or legal inferences for the Assessing Officer. The reopening and consequential reassessment were void ab initio and quashed.....