Assessee-company had entered into definitive agreements with KKR Mauritius as per which KKR invested Rs. 500 crores in assessee-company and was allotted 3.79 crores equity shares. These shares were bought back by DBL, holding company for a sum of Rs. 1218 crores.  Subsequently, Assessing Officer received information from investigation wing that investment pumped in by KKR Mauritius was assessee’s own black money and that there had been round tripping since later KKR’s shareholding in assessee-company was bought back by holding company and that whole transaction needed to be investigated properly to find out if any black money had been used in transaction. Assessing Officer issued reopening notice. Audit report of assessee specifically noted that holding company as well as assessee had entered into definitive agreements, namely, share subscription agreement and shareholders agreement with KKR Mauritius.   Single judge allowed the the writ petition against reassessment notice. On appeal by the revenue the Court held that  copies of share subscription agreement and shareholders agreement were not placed before Assessing Officer.  Since full contours of arrangement between KKR Mauritius and assessee-company were not placed before Assessing Officer in first instance, there was failure on part of assessee to fully and truly disclose material facts there was sound basis for reasonable belief entertained by Assessing Officer for issuing notice under section 148. Order of single judge is set aside. (AY. 2011-12)