Allowing the petition the Court held that the reasons recorded for reopening the assessment and the order disposing of the objections raised by the assessee for the reopening of the assessment were one and the same. The records indicated that the assessee had duly deducted and paid the tax deducted at source on these payments of interest and finance charges and copies of the accounts of these parties had been tendered at the time of assessment and with the objections to the reopening. There was material available with the Assessing Officer and the assessee had not suppressed or withheld any information at the time of assessment proceedings and on this score itself, the notice of reassessment could not be sustained.  That there was no whisper in the order as regards any failure on the part of the assessee to disclose fully and truly all material facts and no such failure on the part of the assessee could be inferred from the reasons recorded. The assessee had made adequate disclosures during the assessment proceedings. Accordingly, the notice and order disposing of the objection were quashed. Relied on  Ganga Saran and Sons (P) Ltd. v. ITO (1981)  130 ITR 1 (SC)  AY. 2011-12)