Tribunal held that for assumption of jurisdiction, in the reasons recorded, the Assessing Officer had stated that the assessee had failed to fully and truly disclose all material facts necessary for the assessment. What material facts had not been disclosed by the assessee had not been spelt out by the Assessing Officer. The Assessing Officer had himself stated that the assessee had credited capital gains on sale of agricultural land in its profit and loss account and had reduced them while working out the book profits under section 115JB . Therefore, all the primary facts had been duly disclosed by the assessee and it was for the Assessing Officer to draw correct legal inference therefrom. Further, the proviso to section 147 was not applicable in the instant case as the notice under section 148 had been issued within four years from the end of the assessment year 2013-14. Thus the basic requirement for assumption of jurisdiction under section 147 was not satisfied in the instant case and the consequent reassessment proceedings deserved to be set aside. Tribunal  also held that  the decision of the Tribunal had since been affirmed by the Rajasthan High Court. Undisputedly, there was no change in the facts and circumstances of the case and therefore, the matter was decided in favour of the Department. Followed  CIT v. Usha International Ltd. (2012)  348 ITR 485 (FB)  (Delhi)(HC).  Tribunal also held that  gains on sale of agricultural land were not deductible while computing book profits. Relied on Krish Homes P. Ltd. v. ITO (2020)421 ITR 105 (Raj) (HC) on special leave petition (2020)420 ITR (St.) 2 (SC)  ( AY.2013-14)