Allowing the petition the  Court held that Notice u/s. 148 of the Act was without jurisdiction as there was no new tangible material was available with the AO and reassessment was initiated on the basis of material which was already available on the record. Reassessment initiated beyond 4 years. Specific query was raised by the AO during the course of original assessment and AO had asked assessee to justify the lump sum compensation of Rs. 135 Lakhs debited by the assessee in the Profit and Loss Account. Assessee submitted Audit Report and filed letter dated 03.11.2014 and furnished copy of the order of the court and related documents to justify the Lump Sum Compensation paid. Assessee further filed letter dated 22.12.2014 and furnished MoU entered into between the petitioner and Ratna Developers, ledger account of Lump Sum Compensation account of Ratna Developers and Bank Statements earmarking the payment made to Ratna Developers. AO was satisfied and did not make any additions and assessment u/s. 143(3) of the Act was completed. Notice u/s. 148 of the Act dated 30.03.2019 issued on the petitioner was quashed as reopening was not based on any new tangible material. Further, the twin condition i.e. existence of new tangible material and failure on the part of the assessee to disclose all material facts (truly and fully), does not exist. Thus, the Court held that jurisdiction under section 148 cannot be exercised. (AY 2012-13)