Reassessment beyond four years needs fresh tangible material; reopening on already disclosed sales and purchase figures was invalid.

Reopening of assessment beyond four years under section 147 requires a jurisdictional showing that the assessee failed to fully and truly disclose all material facts. Where the notice under section 148 was based on the same sales and purchase statements already filed in the original section 143(3) proceedings, and the recorded reasons reflected only an arithmetical reworking of existing figures without fresh tangible material, the reassessment amounts to mere reappraisal of disclosed material. On those facts, the assumption of jurisdiction under section 147 was held invalid and the reassessment was not sustainable.

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Issues: Whether the reassessment under section 147 was valid when the original assessment had been completed under section 143(3) and the notice under section 148 was issued beyond four years from the end of the assessment year.

Analysis: The reassessment was founded on the same sales and purchase statements that had already been furnished during the original assessment proceedings. The reasons recorded did not refer to any new tangible material and proceeded only on an arithmetical reworking of the already disclosed figures. In a case reopening assessment beyond four years, the jurisdictional requirement of failure by the assessee to disclose fully and truly all material facts must be satisfied. On the facts, the material relied upon had already been placed before the Assessing Officer, and the reopening was thus based on reappraisal of existing material rather than fresh information.

Conclusion: The assumption of jurisdiction under section 147 was invalid and the reassessment was not sustainable.

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