Where the assessee-company had been assessed as a domestic company for assessment year 2014-15 and the Assessing Officer subsequently sought to reopen the assessment on the basis of a tax residency certificate furnished during scrutiny proceedings for assessment year 2016-17, contending that the assessee ought to have been taxed at the rate applicable to a foreign company, the High Court held that there was no allegation of any failure on the part of the assessee to fully and truly disclose material facts necessary for assessment and, therefore, the reopening notice was liable to be set aside. (AY. 2014-15).