Allowing the appeal of the asssessee the Court held that there was no tangible material with the Assessing Officer for the purpose of reopening the assessment except the change of opinion that the deductions could not have been claimed and allowed. The conveyance deed, permission of the appropriate authority to sell the property and other documents were filed by the assessee at the time of original assessment proceedings. Nothing was suppressed. Form 37-I speaks for itself. The Commissioner (Appeals) recorded a finding of fact that there was no failure on the part of the assessee to disclose fully and truly all the material facts necessary for the assessment. Such finding of fact could not have been disturbed by the Appellate Tribunal without any basis. The notice of reassessment was not valid.( AY.1991-92)