The Assessing Officer’s reasons for reopening referred solely to the failure to digitally file the audit report in Form 10CCB. Failure to digitally upload a form, when the audit report had in fact been furnished and was available for scrutiny, could not be equated with failure to make a full and true disclosure under section 147; therefore, reassessment notices dated March 26, 2019, and subsequent reassessment proceedings for AYs 2013–14 and 2014–15 were invalid. PCIT v. Wipro Ltd. (2022) 466 ITR 1 (SC), distinguished; CIT v. G.M. Knitting Industries Pvt. Ltd. (2015) 376 ITR 456 (SC), applied.(AY. 2013–14, 2014–15)