Reassessment beyond four years fails where reopening rests on borrowed satisfaction and no failure to disclose material facts is shown.

Reassessment beyond four years was treated as invalid where the recorded reasons merely repeated Investigation Wing material and showed no independent application of mind by the Assessing Officer. The reopening also failed because the precondition of a full and true disclosure failure was not established on the original assessment record, which had already been completed under section 143(3). The reasons proceeded on mistaken factual assumptions, including an incorrect link to another entity and an unsupported claim that relevant documents had not been furnished earlier. Denial of cross-examination further reinforced the defect, and the reassessment notice, proceedings and resulting addition were set aside as bad in law.

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Issues: Whether the reassessment under sections 147 and 148 was valid when it was founded only on Investigation Wing information and whether the assessee had failed to make full and true disclosure of material facts in the original assessment.

Analysis: The recorded reasons merely echoed the investigation material and did not show an independent application of mind by the Assessing Officer. The reasons also proceeded on factual assumptions inconsistent with the original assessment record, including an erroneous linkage with another entity and a mistaken premise that relevant details and documents had not been furnished earlier. Since the assessment had already been completed under section 143(3), reopening beyond four years required a clear showing of failure to disclose fully and truly all material facts, which was not established. The denial of cross-examination further reinforced the infirmity, but the reassessment was principally vitiated because the jurisdictional condition for reopening was absent.

Conclusion: The reassessment notice and proceedings were invalid and the reopening was held bad in law.

Final Conclusion: The addition did not survive and the reassessment order was set aside.

Ratio Decidendi: Reassessment beyond four years cannot be sustained on borrowed satisfaction or vague investigation material unless the Assessing Officer independently forms a bona fide belief, supported by tangible material, that the assessee failed to fully and truly disclose material facts necessary for assessment.

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