Allowing the petition the Court held that the notice of reassessment had been issued after four years. There was nothing in the notice of reassessment to spell out failure on the part of the assessee to disclose fully and truly all material facts. The assessee had disclosed all primary facts. It was clear from the notice that on account of an internal audit objection a remedial action of reopening the assessment by action under section 148 of the Act was taken. The notice and order disposing the objection is quashed. (AY. 2015-16)