Held, dismissing the writ petition, that from the reasons for initiating the process of reassessment, it could be seen that the facts regarding the assessee’s dealings with shell companies for routing its own unaccounted money into its books of account had not been truly and fully disclosed by the assessee during the original assessment and scrutiny assessment, though the information was embedded in the records produced before the Assessing Officer and could be found out on a detailed scrutiny and investigation. There was prima facie material available on record before the Assessing Officer for issuing a notice for reassessment. The notice was valid. At the stage of issue of the notice of reopening of assessment the Court has only to see whether there is prima facie some material on the basis of which the Department could reopen the case. The disclosure must not only be true but must be full-“fully and truly“. (A Y.  2013-14)