Allowing the petition the Court held that the assessee had disclosed full particulars. Despite the assessee having submitted his valuation report dated January 10, 2005 why the request calling for a valuation report was made only on October 19, 2006 and why the report reached the officer on November 5, 2007 were all questions which were not clear from the record. Without meeting the essential ingredients of application of mind to the various material, necessitating reopening of the assessment was missing. The order passed by the Deputy Commissioner under section 143(3) / 147 as also by the Commissioner was set aside. (AY.2004-05)