The Assessee challenged the issue of reassessment notice u/s 148 of the Act. Single judge dismissing the petition held that the intricacies involved in the issues required an elaborate adjudication. The assessee was a large taxpayer unit and certain intricacies in deeper manner requires more adjudication with reference to the issues raised.  On appeal the division Bench held that, the AO while disposing the objections has accepted the fact that the grounds on which the assessment was reopened were verified by the Assessing Officer while completing the assessment under section 143(3) of the Act. In the absence of new facts coming to the knowledge of the AO subsequent to the original assessment proceedings the reopening could not have been done on the basis of same material. Referred Circular No. 549 dt. 31^st October, 1989 (1990) 181 ITR 35 (St). Writ petition is allowed, order of single judge is set aside. (AY. 2013-14)