Dismissing the petition the Court held that the reasons for reassessment in both the cases revealed clearly the specific details of the allegedly offending transactions. The reasons disclosed the receipt of information that was hitherto unavailable with the assessing authority. Though it was the specific case of the assessee that the materials relied upon were available on record even at the first instance, there was nothing on record either by way of correspondences or any other material from the assessee to indicate this. The materials referred to in the reasons constituted new and tangible material, unavailable at the first instance to the officer. It was such information, as supplied by the Director-General, Investigation, that the officer had considered to arrive at his prima facie belief that income may have escaped assessment to tax. The assessing authority referred to material received from the Director-General, Investigation bringing to his notice information relating to the allegedly offending share allocation and pricing. This constituted tangible material on the basis of which jurisdiction had been assumed. The notices of reassessment were valid. (AY-2008-09, 2009-10)( SJ)