Allowing the petition the Court held that the Assessing Officer had proceeded on entirely a new set of facts which were never put to the assessee in the show-cause notice and the corrigendum issued thereto. The reassessment proceedings had to be redone even though the assessment order under section 147 had been passed.  The order is set aside. The assessee has  to submit a comprehensive and detailed reply to all the allegations which were made against him and produce documents in support of his claim. The assessee is  entitled to seek for required documents in this regard and the period of time fixed in this order would commence from the date on which the assessee received those documents from the Department. Thereafter the Assessing Officer should afford an opportunity of hearing to the assessee and redo the proceedings in accordance with law.