The assessee, a real estate developer, claimed a deduction for interest expense on borrowed funds, which was allowed in the scrutiny assessment order passed under section 143(3). After the expiry of four years from the end of the relevant assessment year, the assessment was sought to be reopened on the ground that the interest should have been capitalised to work-in-progress and would be allowable as deduction in the year in which the corresponding income was offered for taxation. The High Court quashed the proceedings, holding that the precondition for reopening an assessment after four years-failure on the part of the assessee to disclose fully and truly all material facts-was not satisfied. Since the assessee had made a full and true disclosure of all primary facts during the original assessment, the Assessing Officer was not entitled to reopen the assessment based on a mere change of opinion on the same set of facts.(AY. 2012-13)