Allowing the petition the Court held that,  the reasons for reopening were based on two heads, namely, “asset written off and factory land development charges”. It was not the case of the Revenue that the amount referable to those two heads were not shown in the profit and loss account. On the other hand, the assessee had enclosed along with the return its trading, profit and loss account wherein these two heads were specifically shown with the referable quantum of amount. It was evident that the materials relevant to the subject matter in issue for reopening, were already on record before the Assessing Officer. After perusing the return filed along with its enclosures, the Assessing Officer had completed the assessment. Therefore, there was a reasonable presumption that the Assessing Officer had accepted the materials filed with the returns except to the extent where he differed and had stated so in his assessment order. Neither the notice issued under section 148 nor the proceedings stating the reasons for reopening the assessment, had alleged anywhere that the assessee had failed to disclose fully and truly any material facts necessary for assessment. The notice of reassessment was not valid. ( Girilal and Co v ITO  ( 2016) 387 ITR 122 (SC)  & A. Sridevi (Smt) v ITO ( 2018) 409 ITR 502 (Mad) (HC) is distinguished . AY.2011-12)