Where an assessment completed under section 143(3) was sought to be reopened after the expiry of four years on the grounds that interest on capital work-in-progress should have been capitalised under the proviso to section 36(1)(iii) and that ground rent was misclassified, the High Court quashed the notice. It was held that since the Assessing Officer had derived the information for forming his reasons from the balance sheet and computation of income filed by the assessee with its return, all primary facts were already on record. Therefore, there was no failure on the part of the assessee to disclose fully and truly all material facts, which is a jurisdictional prerequisite for reopening an assessment beyond the four-year limitation. (AY. 2007-08)