The assessee was engaged in a shipping business. Assessee completed its assessment for A.Y. 2012-13 and the same was accepted u/s 143(3).  The AO reopened the assessment u/s 147 and issued notice for the same. The AO transferred the matter related to international transactions to a Transfer Pricing Officer. The assesee filed its objection against the draft assessment order to the Dispute Resolution Panel. Finally, the total income calculated as per the provisions of the Act exceeded the book profits, the AO demanded tax on the total income. The validity of reopening the assessment was challenged.  The Tribunal held that the assessment had been reopened after the expiry of four years from the end of the assessment year. There was no failure on the part of the assessee in disclosing all material facts relevant to the computation of income fully. When the assessee had duly furnished all the material facts before the Assessing Officer, it was for the Assessing Officer to decide the manner of examining those details. If there was failure on the part of the Assessing Officer, that could not be a ground for reopening the assessment after the expiry of four years from the end of the assessment year, when the original assessment was completed under section 143(3) of the Act. Hence the order of the AO is liable to be quashed. (AY.2012-13)