Allowing the petitions, that in the absence of any new information or material which did not form part of the original assessment proceedings, it was not open to the Assessing Officer to frame a fresh assessment, that too, in a case where the notice of reopening had been issued beyond a period of four years. The legal conclusions on the basis of the factual analysis the Assessing Officer had arrived at, were based on the material already on record during previously reopened assessment proceedings. The reasons proceeded concededly only on the material available on record. Such relevant material included the notings in the assessee’s diary which recorded a figure of Rs.5,96,914 as outstanding fees to be collected and other entries referring to certain outstanding payments. Permitting the Assessing Officer to re-examine the entire issue once again, looking at the materials on record from a different angle would destroy the very concept of finality of an assessment order which could be permitted only on legally recognized grounds. The notices issued under section 148 for reopening the assessment were to be set aside.( AY.2010-11)