Section 68 & 147 of the Income Tax Act, 1961—Cash credit — Notice issued under section 147 was invalid as the notice is beyond a period of four years from the end of the relevant Assessment Year and therefore governed by first proviso of Section 143(3) and the very issue on which the Assessing Officer has come to a reason to believe that income chargeable to tax has escaped assessment were subject matter of examination leading to an order under Section 143(3), thus, there was no failure on the part of the assessee to disclose truly and fully all material facts necessary for the assessment. Besides, it is submitted that this is a clear case of change of opinion, as the Assessing Officer had already taken a view on the facts alleged in the reasons — Uni vtl precision (p.) ltd. vs. Dy. CIT. [2020] 269 TAXMAN 278 (BOM).