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)   .(WP No. 2840 of 2022 dt .10 -2 -2023 ) (AY. 2015 -16 )