Reassessment reopening beyond four years fails where recorded reasons do not specify withheld material facts.

A reassessment notice issued beyond four years from the end of the assessment year cannot be sustained unless the recorded reasons themselves clearly identify the material facts allegedly not fully and truly disclosed by the assessee. The first proviso to Section 147 requires a specific, reasoned assertion of failure to disclose, and that requirement cannot be cured by later affidavit or oral submissions. Because the recorded reasons did not specify the withheld facts, the reopening failed on its own terms and the reassessment notice was quashed.

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Issues: Whether the notice for reassessment issued beyond four years from the end of the relevant assessment year could be sustained when the recorded reasons did not specify the material facts allegedly not fully and truly disclosed by the assessee.

Analysis: The reasons recorded for reopening referred to matters said to have emerged from the case records, but the crucial requirement under the first proviso to Section 147 was not met because the reasons did not identify the specific material facts that were allegedly withheld by the assessee. In the absence of such disclosure in the recorded reasons, the reopening could not be justified by later affidavit or oral submissions, and the reasons had to stand or fall on their own contents. The statutory bar on reopening after four years could be crossed only by a clear and reasoned assertion of failure to disclose fully and truly all material facts necessary for assessment.

Conclusion: The reassessment notice was unsustainable and was quashed.

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