The High Court held that where the original assessment for the relevant year was completed under section 143(3) after a detailed scrutiny of all aspects of the assessee’s share transactions, the reassessment proceedings initiated after the expiry of four years are invalid. The court noted that the foundational reason recorded for reopening-that no scrutiny assessment had been conducted-was factually erroneous. For reopening an assessment after four years from the end of the relevant assessment year, the proviso to section 147 mandates that there must be a failure on the assessee’s part to disclose fully and truly all material facts. Since the assessee had disclosed all particulars of his share trades, which were duly examined in the original assessment, this jurisdictional prerequisite was not met. The mere receipt of subsequent information about ‘client code modification‘ by the stockbroker, without any evidence to show that the assessee was responsible for it or had withheld any material information, cannot justify reopening a concluded assessment. (AY. 2013-14)