Re assessment notice  was issued on 31 st March 2019  to reopen assessment . Ba sis, for reopening was that certain companies were accepting contracts and were sub-contracting those contracts to other entities and revenue came to know about this based on a survey under section 133A of one SEPCL .Assessing Officer had recorded reasons that a contract was received by assessee from one SECPL during relevant assessment year . On writ the Court held that during assessment proceedings, on being asked about details of sub-contract given, assessee had given entire details required by Assessing Officer therefore, it could not be said that there was non-disclosure on part of assessee .  Re assessment notice is held to be bad in law . Referred,   First Source Solutions Ltd v. ACIT ( 2021) 438 ITR 139 ( Bom)( HC)   ( AY. 2012 -13 )