Allowing the petition the Court held that reassessment is based upon a second opinion on the same facts by a subsequent Assessing Officer. A notice under S. 148 was to be premised on fresh or tangible material made available with the Department within the time granted or within the extended time under S. 147 or if material documents, which had significance on the reassessment were withheld or improperly disclosed. The notice for reopening the assessment was quashed. (AY. 2011-12)