Allowing the appeal of the revenue the Court held that, reassessment was made on basis of report of ITO who pointed out that six dealers to whom payments had been made were bogus. Opinion formed for purpose of disallowance to extent of 20% was on incorrect facts and there was no infirmity in re-assessment proceedings. There was acquisition of fresh information, specific in nature and reliable in character relating to concluded assessment in assessee’s case. Income Tax Officer having jurisdiction over area in which certain dealers to whom assessee had made payments were situated made enquiries and found that they were non-existent—Non-disclosure germane to facts was that six dealers were bogus and in regular assessment, no such question raised or enquiry conducted. There was no reason for first appellate authority or Tribunal to interfere with findings of AO.