Reassessment beyond four years barred where reopening rests on the same material and no disclosure failure is recorded.

A completed scrutiny assessment under section 143(3) cannot be reopened beyond four years on the basis of the same material already examined in the original assessment unless the Assessing Officer records a specific failure by the assessee to disclose fully and truly all material facts. Here, the reasons for reopening under section 148 relied only on the existing assessment record and no independent tangible material or disclosure failure was shown. The first proviso to section 147 therefore barred the reassessment, and the reopening was treated as an impermissible change of opinion and an attempt to review a concluded assessment. The reassessment proceedings were quashed in favour of the assessee.

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Issues: Whether reassessment initiated beyond four years from the end of the assessment year was valid when the original assessment under section 143(3) had been completed and the reasons for reopening were founded only on material already available in the assessment record without any recorded failure by the assessee to disclose fully and truly all material facts.

Analysis: The original scrutiny assessment had been completed under section 143(3) after examination of the assessee's books, details, and explanations. The reopening notice under section 148 was issued beyond four years from the end of the relevant assessment year. The recorded reasons were based only on the same assessment record and material already examined in the original proceedings, and no independent tangible material or specific failure to disclose fully and truly all material facts was shown. In such a situation, the first proviso to section 147 bars reopening, and reassessment on the same material amounts to an impermissible change of opinion and an attempt to review a concluded assessment.

Conclusion: The reassessment proceedings were invalid and rightly quashed. The challenge to reopening succeeded in favour of the assessee.

Ratio Decidendi: Where a completed scrutiny assessment is sought to be reopened beyond four years, the Assessing Officer must record a specific failure by the assessee to disclose fully and truly all material facts necessary for assessment, and reopening cannot rest merely on the same material already examined in the original assessment.

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