Allowing the petition the Court held that in the notice for reopening the assessment, the Assessing Officer had not mentioned what was the new tangible material to justify the reopening and what was the material fact which was not truly and fully disclosed. In the absence of any new tangible material available with the Assessing Officer, and in view of the fact that there is a general presumption that an order of assessment under section 143(3) has been passed after proper application of mind and considering the fact that in the present case, the Assessing Officer had sought clarification with regard to the details of sister concerns and all transactions, details whereof were submitted during the course of the proceedings, this showed that the issue with regard to transactions with all parties had been gone into by the Assessing Officer. There was no failure on the part of the assessee to disclose any material facts and consequently the reopening was invalid in view of the proviso to section 147 of the Act. (AY.2013-14 to 2017-18)