The assessment was completed under section 143(3) making certain additions / disallowances. The assessment was reopened after expiry of 4 years from end of relevant assessment year and disallowed relief under section 90, on ground that arrangement of payment had caused revenue loss to government of India. CIT(A) affirmed the order of the AO. On appeal the Tribunal held that  part relief under section 90 was granted under original assessment,  there was no allegation by Assessing Officer that income chargeable to tax had escaped assessment due to failure on part of assessee to disclose fully and truly all material facts. Since there was not even a mention of any new or tangible material which formed basis to believe that income chargeable to tax had escaped assessment, reassessment order is  quashed. (AY. 2012-13)