The assessee’s assessment was completed under section 143(3). After four years, the assessment was reopened on the ground that the assessee wrongly claimed an interest deduction under section 57 instead of section 24, which allegedly amounted to non-disclosure of material facts. The High Court noted that during the original assessment, the Assessing Officer had raised a specific query regarding the loan and its utilisation, to which the assessee had replied. The Court held that once a query is raised and answered, the matter is deemed considered. Since the reopening was based on a re-appreciation of the same facts already on record, it was a mere change of opinion, not a failure by the assessee to fully and truly disclose material facts. Therefore, the jurisdictional condition for reopening the assessment after four years was not met, and the notice was quashed. (AY. 2006-07)