The assessment was reopened beyond four years on the allegation that the assessee had benefited from accommodation entries received through an amalgamated company. The Tribunal found that the Assessing Officer recorded contradictory facts regarding the nature of the transactions and failed to conduct any independent enquiry before recording reasons to believe. There was no material to establish failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment. The reopening was based on borrowed satisfaction and mechanical approval under section 151. Accordingly, the reassessment proceedings and consequential addition under section 68 were held to be invalid. [AY. 2011-12]