Allowing the petition the Court held that the Assessee was possessing a valid approval under section 10B of the Act granted by STPI which was produced before the Assessing Officer and if a ratification by CBDT is to be obtained then the Assessing Officer at the time of original assessment ought to have directed the assessee to get any such ratification certificate for allowing the exemption. It may be a mistake or omission committed by the Assessing Officer. The reassessment proceedings on the ground that the assesee has not disclosed fully and truly all material facts is not established. Assessment beyond period of four years was held to be not sustainable. (AY. 2019-20)