Reassessment notice was issued on  the ground that assessee had debited a sum of certain amount towards profit on sales of barge and since barge was depreciable asset and same should had been deducted from block of assets in category of ships in depreciation chart, said amount debited to profit and loss account was required to be added back while computing total income from business and profession but same was not done. Tribunal held  that reopening was on basis of material already available on record and there was no new tangible material available before Assessing Officer to reopen assessment after expiry of period of four years  and there was  no failure to disclose material facts. Order Tribunal is up held.