The Tribunal held that for AY 2014-15, the assessee had fully and truly disclosed all material facts relating to the transactions resulting in losses and, therefore, the proviso to section 147 was not applicable. Consequently, the notice issued on 28-4-2021 was barred by limitation, and the reassessment was quashed. In respect of AY 2016-17, since the alleged escaped income was only ₹21.78 lakh, section 149(1)(a) permitted reopening only within three years. Accordingly, the notice issued on 30-7-2022 was also held to be barred by limitation, and the reassessment was quashed.