Reassessment beyond four years barred where full disclosure was made and reopening rested on the same facts.

Reassessment initiated beyond four years from the end of the assessment year was barred because the assessee had already disclosed all primary material facts relating to the depreciation claim and lease transactions. The Assessing Officer had called for invoices, lease details and other particulars, and had also issued notices to lessees and suppliers under section 133(6); the assessment was completed on that material. On those facts, there was no failure to disclose fully and truly all material facts, and any omission lay only in the original assessment reasoning. The proviso to section 147 therefore prevented reopening, and the reassessment was held invalid.

---

---

Issues: Whether reassessment initiated after four years from the end of the relevant assessment year was valid when the assessee had already disclosed the material facts relating to the depreciation claim and lease transactions.

Analysis: The original assessment showed that the Assessing Officer had specifically called for invoices, lease details, and other particulars, and had also issued notices to lessees and suppliers under section 133(6). The assessee furnished the required information, and the assessment was completed on that basis. On these facts, there was no failure by the assessee to disclose fully and truly all material facts necessary for assessment. Any omission, if at all, lay in the manner in which the original assessment was framed. In such circumstances, the proviso to section 147 barred reopening after four years.

Conclusion: The reassessment was not valid. The finding was in favour of the assessee.

Final Conclusion: The challenge to the reopening failed, and the reassessment order could not be sustained.

Ratio Decidendi: Reassessment beyond four years is impermissible where the assessee has disclosed all primary material facts and the reopening rests only on a later change of view on the same facts.

---