Reassessment beyond four years stands where fresh material indicates incomplete disclosure and no prior opinion was formed

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....Reassessment beyond four years after a completed scrutiny assessment requires recorded reasons based on tangible material with a live link to escaped income and a failure of full and true disclosure of material facts. A post-assessment investigation concerning alleged share overvaluation, underlying assets, use of sale proceeds and capital-gains deduction supplied a prima facie basis for reopening. Change of opinion applies only where the original proceeding consciously formed an opinion; an intimation under Section 143(1) is not an assessment, and no prior view on the relevant valuation or deduction issues was formed under Section 143(3). The reassessment notices were therefore valid.....