Reassessment beyond four years fails where no nondisclosure is recorded and reopening rests on a mere change of opinion.

Reassessment beyond four years under section 147 requires the recorded reasons to show failure by the assessee to fully and truly disclose material facts; absent that condition, reopening is invalid. The recorded reasons here did not allege any such failure, and the recruitment and training expense material had already been disclosed in the audited financial statements, return, and original assessment record under section 143(3). No new tangible material or external information supported the reopening, so the action rested only on re-examination of the same material. The reassessment was therefore without jurisdiction as a mere change of opinion.

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Issues: Whether reassessment under section 147 of the Income-tax Act, 1961 was valid when initiated beyond four years from the end of the assessment year despite no recorded failure by the assessee to fully and truly disclose material facts, and whether the reopening was based only on a change of opinion.

Analysis: The reasons recorded for reopening did not allege any failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment. The material relating to recruitment and training expenses had already been disclosed in the audited financial statements and in the return of income filed under section 139(1) of the Income-tax Act, 1961, and had been available during the original assessment under section 143(3) of the Income-tax Act, 1961. No new tangible material or external information was identified in the reasons to believe, and the reopening was founded on re-examination of the same material already on record.

Conclusion: The reassessment was without jurisdiction, being based on a mere change of opinion and lacking the mandatory condition for reopening beyond four years.

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