Tribunal held that, the original assessment in the assessee’s case had been completed and the notice was issued after the expiry of four years from the end of the relevant assessment year. The reassessment could have been validly initiated on failure on the part of the assessee to fully and truly disclose all material facts necessary for assessment. A note had been appended to the return at the foot of the schedule reading that additional depreciation at 20 per cent. had been claimed under section 32 , ninth proviso. The assessee did make a disclosure of the claim of additional depreciation. Moreover, the Assessing Officer while finalising the assessment, did take note of this fact, and did not allow travelling expenses incurred for purchase of new plant and machinery and treated such amount as capital expenditure. He not only allowed depreciation but also additional depreciation on such amount Therefore, not only had the assessee made disclosure of the claim of additional depreciation in the original return but the Assessing Officer was conscious of the same fact and had accepted such claim. The case was covered by the first proviso to section 147 . Therefore, the initiation of reassessment proceedings was set aside.( AY.2006-07)