Sec. 147 of Income Tax Act, 1961— Re-assessment - The assessment is sought to be reopened beyond a period of four years from the end of relevant assessment year, in the absence of any failure on the part of the petitioner to disclose truly and fully all material facts necessary for its assessment, the basic requirement for taking action under section 147 of the Act as postulated in the first proviso thereto, is not satisfied. During the course of scrutiny assessment, the AO had examined the claim for deduction under section 80IB(10) of the Act in detail, therefore, merely because he did not examine such claim from the angle of clauses (e) and (f) thereof, would not be a valid ground for reopening the assessment as it would amount to a mere change of opinion. Under the circumstances, the assumption of jurisdiction by the AO under section 147 of the Act, by issuing notice under section 148 of the Act is invalid, which renders the impugned notice unsustainable. The petition of the assessee allowed. - ROYAL INFRASTRUCTURE V/s DEPUTY CIT - [2020] 425 ITR 491 (GUJ).