Dismissing the appeal of the Revenue  the Court held that  no fresh tangible material had come into the possession of the Assessing Officer before recording the reasons for reopening the assessment. Even in the recorded reasons, the Assessing Officer clearly stated that his observations were based “on a perusal of records” and no fresh or new tangible material had been referred to or brought on record. The Tribunal was right and the notice of reassessment was not valid.(AY.2008-09)