Reassessment beyond four years barred where reopening relied on material already examined and amounted to a change of opinion.

Reopening beyond four years after scrutiny assessment under section 143(3) was barred because the recorded reasons relied on the same material already examined in the original assessment. The issue of alleged bogus or accommodation purchases had been specifically called for, disclosed, and considered during the regular assessment, and no new tangible material or independent investigation emerged later. In the absence of any failure by the assessee to fully and truly disclose material facts, the first proviso to section 147 applied and the reassessment amounted to a mere change of opinion. The reassessment was therefore held invalid and quashed.

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Issues: Whether reassessment initiated beyond four years from the end of the relevant assessment year was valid when the original assessment had been completed under section 143(3) and the recorded reasons were based on material already available in the assessment record, and whether such reopening was merely a change of opinion.

Analysis: The reopening was founded on alleged bogus purchases from three parties, but the reasons recorded showed that the Assessing Officer relied on the very same assessment records and materials already examined in the original scrutiny assessment. The order sheet entries demonstrated that the issue of hawala or accommodation purchases had been specifically called for, examined, and the supporting details had been furnished during the regular assessment. In such circumstances, where the assessee had disclosed all primary facts and there was no new tangible material or independent investigation after completion of scrutiny, the first proviso to section 147 barred reopening after four years. The Court treated the action as an impermissible re-examination of the same material and applied the settled principle that reassessment cannot be used to correct an earlier view in the absence of failure to disclose fully and truly all material facts.

Conclusion: The reassessment was invalid and was quashed. The legal grounds challenging reopening were decided in favour of the assessee.

Ratio Decidendi: Where an assessment has been completed under section 143(3), reopening beyond four years is impermissible unless the recorded reasons disclose a failure by the assessee to fully and truly disclose material facts necessary for assessment, and a mere reappraisal of already examined material amounts to change of opinion.

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