Allowing the petition, the Court held that the Assessing Officer sought to reopen assessment of assessee after period of four years on ground that assessee had transferred the funds with certain company which had been conclusively proven to be a shell company, since Assessing Officer had reopened assessment solely on basis of ‘reason to believe’ and not on grounds of failure to disclose material facts fully and truly, and moreover, Assessing Officer failed to highlight in reasons recorded as to what was that material fact, which was not disclosed by assessee in its return, impugned reopening notice and consequent order was quashed. (AY. 2015-16)