Reassessment after four years requires fresh material, full disclosure failure, and valid sanction; change of opinion is impermissible.

Reassessment after four years from a completed assessment under section 143(3) requires the Revenue to establish failure by the assessee to fully and truly disclose material facts, together with valid sanction under section 151(1). Where the recorded reasons show only reappraisal of material already on record and no fresh tangible material, the reopening amounts to an impermissible change of opinion. On these facts, the reassessment notice and proceedings were invalid, the consequential addition could not survive, and the completed assessment was set aside.

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Issues: Whether the reassessment notice and proceedings were valid where the original assessment had been completed under section 143(3), the reopening was beyond four years, and the record did not show the requisite approval and statutory preconditions for reopening.

Analysis: The reassessment was initiated after the expiry of four years from the end of the assessment year. In such a situation, the first proviso to section 147 required the Revenue to show failure by the assessee to make a return or to disclose fully and truly all material facts necessary for assessment. The reasons recorded reflected only a reappraisal of material already on record and did not disclose any fresh tangible material. The record also showed an inconsistency in the notice and the approval process, and the defect regarding the necessary sanction under section 151(1) was not satisfactorily answered. On these facts, the reopening amounted to an impermissible review of the completed assessment.

Conclusion: The reassessment proceedings were invalid and were rightly quashed. The consequential addition could not survive.

Final Conclusion: The assessee succeeded on the jurisdictional challenge to reopening, and the assessment was set aside in full.

Ratio Decidendi: Where an assessment completed under section 143(3) is reopened after four years, reopening is lawful only if the Revenue establishes a statutory failure of disclosure and a valid sanction under the Act; absent fresh tangible material, the action is a prohibited change of opinion.

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