Where an assessment completed under Section 143(3) was sought to be reopened by a notice under Section 148 issued after four years from the end of the relevant assessment year, the High Court quashed the notice. The Assessing Officer’s reasons for reopening-alleging excess investment taxable under Section 69, disallowance of interest on borrowed funds, and an incorrect adjustment of a disallowance under Section 14A were based entirely on a review of the financial statements and documents already submitted by the assessee during the original assessment. The Court held that since all material facts had been fully and truly disclosed, the reopening was based on a mere change of opinion by the Assessing Officer. Therefore, it was barred by the proviso to Section 147, which requires a failure to disclose material facts on the part of the assessee for a reopening after four years. (AY. 2015-16)