Reassessment beyond four years requires specific recorded failure to disclose material facts; vague reasons cannot sustain reopening.

Reassessment initiated beyond four years was invalid because the recorded reasons did not specifically show that escapement of income resulted from the assessee's failure to fully and truly disclose all material facts. General references to a list and alleged accommodation entries, without particulars or supporting assessment-record material, were held too vague to satisfy the proviso to Section 147 or the statutory requirement of reasons to believe. The reopening therefore lacked jurisdiction and could not be sustained.

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Issues: Whether reassessment initiated beyond four years was valid in the absence of a recorded failure by the assessee to disclose fully and truly all material facts necessary for assessment, and whether the recorded reasons constituted sufficient reasons to believe.

Analysis: The reassessment was sought to be reopened after the expiry of four years from the end of the relevant assessment year, so the proviso to Section 147 required a clear recorded foundation that the escapement of income was attributable to the assessee's failure to make full and true disclosure. The recorded reasons referred only generally to a list and alleged accommodation entries, but they did not contain the details of that list, any specific material showing nondisclosure, or a clear allegation of failure to disclose material facts. The reasons were also found to be vague and unsupported by the assessment record, and therefore did not satisfy the statutory threshold for reopening under the extended limitation period.

Conclusion: The reassessment was invalid, and the reopening could not be sustained.

Ratio Decidendi: Where reassessment is initiated beyond the prescribed four-year period, the recorded reasons must specifically disclose that escapement of income resulted from the assessee's failure to fully and truly disclose all material facts; vague or general references are insufficient to confer jurisdiction.

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