Allowing the appeal of the assessee the Tribunal held that there was no allegation made by the Revenue that income had escaped assessment. There was also no allegation that the assessee had failed to disclose fully and truly all material facts for the assessment in the absence of which no power is vested upon the Assessing Officer to reopen/reassess or recompute income. Therefore, there was no justification for reopening of assessment after expiry of four years from the end of the relevant assessment year. The reopening was bad in law, arbitrary, erroneous since there was no allegation of failure on the part of the assessee in fully and truly disclosing material facts as stipulated by the first proviso to section 147 of the Act.(AY.2011-12)