Assessment was completed under S 153A, read with section 143(3) of the Act. After expiry of four years from end of relevant year, AO initiated reassessment proceedings on ground that seized documents disclosed that assessee had cash in hand of Rs. 20 lakhs which did not form part of assessee’s return and, thus, escaped assessment. On writ the Court held that AO was in possession of all relevant documents at time of assessment, there being no failure on part of assessee to disclose fully and truly all material facts, initiation of reassessment proceedings merely on basis of change of opinion was not justified. The fact that the assessee did not disclose the material is not relevant if the AO was otherwise aware of it. If the AO had the information during the assessment proceeding, irrespective of the source, but chooses not to utilize it, he cannot allege that the assessee failed to disclose truly and fully all material facts & reopen the assessment .  ( WP No. 3546 of 2018, dt. 05.04.2019)  (AY. 2011-12)