Sole ground on which the Assessing Officer desired to reopen the assessment was in relation to the assessee's valuation of closing stock. According to the Assessing Officer, unutilized CENVAT credit should have been included in the closing stock which would alter the assessee's profit for the year under consideration. The documents on record would however show that the entire issue of assessee's treatment of such unutilized CENVAT credit while computing the valuation for the closing stock had come up for minute scrutiny during the original assessment proceedings. The Assessing Officer was conscious of the methodology adopted by the assessee. He had raised multiple queries which we have reproduced. The assessee had replied to such queries. The replies of the assessee have already been reproduced. It was only after such scrutiny that the Assessing Officer had passed the order of assessment, in which, after recording detailed reasons, he made limited disallowance in relation to the unutilized CENVAT credit. We are informed that even this disallowance is a subject matter at the ends of the assessee. With this aspect we are however not directly concerned This quite apart, the impugned notice has been issued beyond a period of four years from the end of relevant assessment year. Clearly, there was no failure on the part of the assessee to disclose truly and fully all material facts necessary for assessments. The Assessing Officer in the reasons recorded, referred to the material which was already on record during the course of assessment. On this ground also, notice must be quashed