Tribunal held that  reopening notice was issued against assessee on ground that a sum of certain amount consisting of two items i.e. liabilities taken over by Government of India and certain amount of reduction claimed from cost of borrowings, was not brought to tax, since there was no failure on part of assessee to fully and truly disclose all material facts necessary for assessment during original assessment proceedings and there was no mention of any fresh tangible material coming into possession of Assessing Officer, impugned reopening of assessment was unjustified. (AY. 2003-04)