The original assessment was completed under section 143(3) of the Act. the reassessment notice was issued on 30-3-2021, on the ground that the advance payment of Rs.17,76,08,505 remained unexplained. The assessee filed the objection for reassessment notice and recorded reasons stating that there was no failure to disclose material facts. The AO passed the order rejecting the objections of the assessee. The assessee filed writ before the High Court. Allowing the petition the Court held that the Assessing Officer has not established that there was a failure on the part of the assessee to disclose all material facts. The Assessing Officer has no power to review. On the facts there is neither a new information received nor has reference been made to any new material on record. Accordingly the notice under section 148 of the Act and all connected proceedings are quashed. Followed, CIT v. Kelvinator of India Ltd (2010) 320 ITR 561 (SC),Jindal Photo Films v.Dy.CIT (1998) 234 ITR 170 ( Delhi)( HC). (AY. 2015 -16 )