The assessment was completed under section 143(3) of the Act by an order dated December 10, 2008. After the assessment was completed, by the Finance (No. 2) Act, 2009 certain amendments were made to section 115JB of the Act with retrospective effect from April 1, 2001. On the date when the assessee filed the returns under section 139 of the Act, i. e., on November 4, 2006, there was no provision which warranted the amount provisioned as bad and doubtful debts to be added to the book profits for the computation of income under section 115JB. The assessee had filed returns based on the understanding of law as it stood at the time of filing of returns on November 4, 2006. Therefore, it could not be said that there was failure on the part of the assessee to truly and fully disclose all materials that are required for assessment. In fact the assessment was also completed based on the understanding of law as it prevailed then. The notice of reassessment after four years was not valid. (AY. 2006-07)