Where the original scrutiny assessment under section 143(3) was completed on 26.03.2015 and the Assessing Officer, after considering all documents, had allowed the business loss and unabsorbed depreciation to be carried forward, a notice under section 148 was issued after the expiry of four years. The reason for reopening was that interest on borrowed funds should have been capitalised to Work in Progress instead of being allowed as an expense. The High Court observed that this reason was derived from a ‘perusal of the case records’ and there was no allegation of any failure by the assessee to disclose material facts. It held that to reopen an assessment after four years, the proviso to section 147 requires a failure to fully and truly disclose material facts. Since this condition was not met, the reopening was based on a mere change of opinion and was invalid. The notice was therefore quashed. (AY. 2012‑13)