Assessee, engaged in the business of real estate development, filed its return of income and had submitted that it had received a loan from a Mauritius-based company. Assessing Officer accepted the same and passed an assessment order. After conclusion of assessment proceedings, the Assessing Officer sought to reopen assessment on the ground that information was received that the assessee had received certain funds as a loan from an entity located in Cyprus and Mauritius, which was routed through various companies located in tax havens and said companies had a connection with the assessee and its directors. On writ, dismissing the petition, the Court held that the said information was not available at the time of the original assessment proceedings and, thus, this information constituted tangible material to reopen assessment. Further, circuitous movement of funds through various companies located in tax havens had not been disclosed in the course of the original assessment proceedings; therefore, even though there was no statement of any allegation of failure to disclose fully and truly all material facts necessary for assessment, the same could be culled out on a reading of the reasons recorded. Accordingly, the reassessment proceeding was upheld. (AY. 2019-10)