No reassessment after 4 years alleging wrong allowance of exp. if assessee had disclosed all materia

IT : Where assessment in case of assessee was completed under section 143(3) wherein assessee's claim for salary paid to partners was allowed, in absence of assessee's failure to disclose all material facts necessary for assessment, Assessing Officer could not initiate reassessment proceedings on basis of change of opinion that claim for payment of salary was wrongly allowed