Full and true disclosure bars reassessment beyond four years where reopening merely reappraises previously scrutinised property-sale material.

Reassessment after four years from a scrutiny assessment under Section 143(3) requires escaped income to result from the assessee's failure to disclose fully and truly all material facts. Where the property sale, stated consideration, stamp-duty valuation, and explanation were specifically examined and furnished in the original scrutiny, reopening cannot rest on a reassessment of the same material or a later view on Section 50C. In the absence of any identified non-disclosure, the reassessment notice was invalid.

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Issues: Whether reassessment of a scrutiny assessment beyond four years was valid where the property-sale transaction and material facts had been disclosed during the original assessment.

Analysis: The first proviso to Section 147 permits reopening, after expiry of four years from the end of the relevant assessment year where an assessment was completed under Section 143(3), only if escaped income is attributable to the assessee's failure to disclose fully and truly all material facts. The sale transaction, stated consideration, stamp-duty valuation component, and explanation for that component had been specifically sought and furnished during the original scrutiny. The recorded reasons identified no material fact withheld by the assessee. Reappraisal of the same disclosed material, including a subsequent view on applicability of Section 50C, could not satisfy the statutory jurisdictional condition.

Conclusion: The reassessment notice issued beyond four years was invalid for want of failure by the assessee to make full and true disclosure of material facts; the finding is in favour of the assessee.

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