Reassessment initiated beyond four years requires failure by the...

Reassessment initiated beyond four years requires failure by the assessee to disclose fully and truly all material facts relating to the recorded escapement of income. Explanation 3 to section 147 permits assessment of other escaped income discovered during valid reassessment proceedings, but does not expand the jurisdictional basis for reopening or sustain proceedings when no addition is made on either recorded ground. Where the recorded reasons yield no addition and the requisite failure of disclosure is not established, the reopening lacks jurisdiction. The reassessment was quashed, and the Revenue's appeal was dismissed.