Allowing the petition the Court held that   there was nothing disclosed in the reasons recorded as to what was not disclosed by the assessee during the block assessment proceeding. The Assessing Officer had issued notice before passing assessment order under section 143(3) read with section 153A to which the assessee had responded providing all documents including the share purchase agreement and the issue had been discussed before passing the order accepting the returned income. In the order disposing of the objections of the assessee for reopening the assessment under section 147, the Assessing Officer had stated that in the original assessment, that he had missed to take into consideration the law laid down in Sumeet Taneja v. CIT (I. T. A. No. 293 of 2012, dated August 22, 2013 (P& H)(HC) and that could not be a reason to reopen the assessment to remedy the error resulting from this oversight. Since the reasons recorded for reopening the assessment did not indicate any failure on the part of the assessee to disclose fully and truly all material facts, notice under section 148 was quashed and set aside. Followed Calcutta Discount Co. Ltd. v. ITO (1961) 41 ITR 191 (SC)  (AY.2013-14)