Reassessment beyond four years fails without recorded non-disclosure; third-party excel evidence alone cannot sustain addition.

Reassessment beyond four years was barred because the recorded reasons and section 148A(d) order did not allege that the assessee failed to disclose fully and truly all material facts, which was fatal to jurisdiction under the proviso to section 147. Notice under section 148 was also invalid because it was issued by the Jurisdictional Assessing Officer instead of through the faceless allocation mechanism under section 151A and the applicable scheme, rendering the reopening void ab initio. An addition under section 69A based only on an unsigned third-party excel sheet, without corroboration, cross-examination, or proper electronic evidence compliance, was unsustainable. A section 143(2) notice was not invalid merely because it did not specify the scrutiny category, as the CBDT instruction was treated as administrative.

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Issues: (i) whether reassessment beyond four years was barred for want of any allegation that income escaped assessment because of the assessee's failure to disclose fully and truly all material facts; (ii) whether notice under section 148 was invalid as being issued by the Jurisdictional Assessing Officer instead of through faceless allocation; (iii) whether the addition under section 69A based solely on an unsigned third-party excel sheet was sustainable; and (iv) whether the notice under section 143(2) was invalid for not specifying the scrutiny category.

Issue (i): whether reassessment beyond four years was barred for want of any allegation that income escaped assessment because of the assessee's failure to disclose fully and truly all material facts.

Analysis: The original assessment had already been completed under section 143(3), and the reassessment was initiated after expiry of four years from the end of the relevant assessment year. The recorded reasons and the order under section 148A(d) did not allege any failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment. That omission went to the root of jurisdiction under the proviso to section 147.

Conclusion: The reopening was barred by the proviso to section 147 and was invalid.

Issue (ii): whether notice under section 148 was invalid as being issued by the Jurisdictional Assessing Officer instead of through faceless allocation.

Analysis: The notice under section 148 was issued by the Jurisdictional Assessing Officer and not through the National Faceless Assessment Centre in the manner contemplated by section 151A and the applicable faceless scheme. The reassessment, therefore, was initiated by an authority lacking the prescribed jurisdiction under that framework.

Conclusion: The notice under section 148 was invalid and the reassessment was void ab initio.

Issue (iii): whether the addition under section 69A based solely on an unsigned third-party excel sheet was sustainable.

Analysis: The addition rested only on an unsigned excel sheet recovered from a third party. No independent verification, cash trail, corroborative evidence, or statement linking the assessee to the alleged transactions was brought on record. The assessee was not supplied the full material and was denied cross-examination despite request. The electronic material also lacked the required evidentiary certification. In addition, the assessee had produced books, stock records, invoices, agreements, bank records, VAT material, and import-related documents, while the books were not rejected and the corresponding trading results and sales were accepted.

Conclusion: The addition under section 69A was unsustainable in law and on facts.

Issue (iv): whether the notice under section 143(2) was invalid for not specifying the scrutiny category.

Analysis: The CBDT instruction relied upon for this objection was treated as an administrative guideline and not a statutory mandate having the force of law. On that basis, the notice under section 143(2) could not be invalidated on the ground urged.

Conclusion: The challenge to the notice under section 143(2) failed.

Final Conclusion: The reassessment stood annulled, and the impugned addition did not survive.

Ratio Decidendi: Reassessment beyond four years requires a recorded allegation of the assessee's failure to disclose fully and truly all material facts, and a reopening founded only on unverified third-party material without independent inquiry, corroboration, or compliance with natural justice and admissibility requirements cannot be sustained.

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