Allowing the petition the Court held that   where the reasons recorded do not specify any material facts allegedly not disclosed by the assessee and reopening is based only on assessment records already examined in original scrutiny (capital gains), the jurisdictional condition under the first proviso to s. 147 is not satisfied. Reassessment after four years in such circumstances amounts to an impermissible review. Furnishing reasons at the fag end and completing reassessment in haste without properly disposing objections was also held to be unfair and unconstitutional.  Followed Hindustan Lever Ltd. v. R.B. Wadkar  (2004) 268 ITR 332 (Bom) (HC) (AY. 2015-16)