The assessee, a joint venture company of GAIL and NTPC, had filed its return for AY 2013-14 declaring loss, which was assessed under section 143(3). The assessee had claimed expenditure under the head “Wages and salaries”, including Rs. 6.29 crore pertaining to earlier years, on the ground that the liability crystallised during the relevant previous year pursuant to a retrospective salary revision circular issued by NTPC in respect of seconded employees. The Assessing Officer sought to reopen the assessment beyond four years alleging excess claim of expenditure. On writ, the High Court held that the conditions of section 149(1)(b), as substituted by the Finance Act, 2021, were not satisfied since the alleged escaped income was not represented in the form of an asset, the wages and salaries account being only a nominal account. Further, since the original assessment was completed under section 143(3), reopening beyond four years was barred in the absence of any failure on the part of the assessee to disclose fully and truly all material facts. The assessee had specifically disclosed in its accounts that the wages and salaries included prior period liability arising on account of retrospective revision of salaries of seconded employees, and the liability had crystallised during the relevant year. Accordingly, the order passed under section 148A(d), notice issued under section 148 and the reassessment proceedings were quashed. (AY.  AY. 2013-14)