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11. The expressions used in section 147 (a) are for that year" and "any year". These words refer to the assessment year which is the relevant one. These expressions have been used with reference to the failure on the part of the assessee to file a return or to make full and true disclosure of material facts for a specific year. Thus, the provisions of section 147, can be applied where the assessee has failed to file the return under section 139. The proceedings can be initiated for the previous year relevant to any assessment year. In other words, for putting into operation section 147 of the Act, there should be a return under section 139 and the re-opening should pertain to previous year relevant to assessment year. When the assessment is completed under section 172(4) of the Act there is neither any return under section 139 nor any assessment year is involved. As already stated above, there is no previous year in an assessment under section 172(4) of the Act. For the purpose of computation of tax and its recovery under section 172, no return of income is required to be filed under section 139 of the Act. It therefore, appears that the provisions of section 172 are independent of the other provisions of the Income-tax Act. I therefore, agree with the findings of the learned Judicial Member. In my view, the re-assessment machinery under section 147 cannot be put in motion to rectify a mistake, if any, in the assessment completed under section 172(4) of the Act.