Reassessment beyond four years fails where scrutiny assessment already examined the claim and full disclosure was made.

Reassessment beyond four years from the end of the assessment year is invalid where the original scrutiny assessment had already examined the section 10B claim and the assessee had disclosed all primary facts. The Assessing Officer had queried the claim, received supporting documents, and substantially accepted it, so reopening on the same material amounted to a mere change of opinion. In the absence of any failure to fully and truly disclose material facts, the reassessment notice could not be sustained, and the reopening was held to fail in favour of the assessee.

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Issues: Whether the reassessment notice issued beyond four years from the end of the relevant assessment year was valid when the original assessment had been completed after scrutiny and the assessee had disclosed the material facts relating to the claim under section 10B.

Analysis: The original assessment had examined the claim under section 10B in detail, with queries raised and supporting documents produced by the assessee. The Assessing Officer accepted the claim substantially, making only a limited disallowance on a different aspect. In these circumstances, the reopening was based on an issue that had already been scrutinised, and there was no failure by the assessee to disclose fully and truly all material facts. A reassessment notice issued after four years cannot be sustained on a mere change of opinion when the primary facts were already on record and considered in the original proceedings.

Conclusion: The reassessment was invalid and could not be sustained; the challenge to reopening succeeded in favour of the assessee.

Ratio Decidendi: Reassessment beyond four years after a scrutiny assessment is impermissible where the assessee has made full and true disclosure of material facts and the proposed reopening is founded only on a change of opinion.

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