Allowing the petition the Court held that the Assessing Officer could not reopen the assessment after four years where there was no failure on the part of the assessee to disclose fully and truly all the facts necessary for assessment. The record indicated that the assessee had disclosed all materials fully and truly before the authority at the time of original assessment. Even on the merits, it is settled that disallowance under section 14A cannot exceed the exempt income of the assessee. Thus, the twin conditions as provided under section 147 of the Act, which were condition precedent for reopening of the assessment after four years were not satisfied. The proposed disallowance under section 14A exceeded the exempt income and invoking the provisions for reopening of the assessment under section 147 of the Act was bad in law. The notice was not valid. (AY. 2012-13)