Reopening beyond four years after an assessment under section...

Reopening beyond four years after an assessment under section 143(3) was invalid because the recorded reasons did not allege that the assessee had failed to disclose fully and truly all material facts. The reassessment was initiated on Investigation Wing information about client code modification, but the relevant transactions and profit were already reflected in the contract notes and return, indicating no disclosed fraud or new material. The Tribunal treated the exercise as a mere change of opinion, noted that only a gist of reasons was supplied, the Investigation Wing report was not furnished, and no sanction under section 151 was produced. On these cumulative grounds, the reassessment was held illegal.