Reassessment of the existence of a permanent establishment...

Reassessment of the existence of a permanent establishment cannot revisit an issue already examined during scrutiny merely because the assessment order did not expressly record a finding. Where subscription arrangements and the agent relationship were disclosed and considered, reopening would improperly cure the Assessing Officer's failure to record a conclusion, undermining assessment finality. Reopening after four years from a scrutiny assessment also requires failure to make a full and true disclosure of material facts. As that jurisdictional condition was absent and the notice was issued beyond the statutory six-year period, the reassessment notice was quashed without deciding whether a permanent establishment existed in India.