Held that the assessment  was reopened not for any failure on the part of the assessee to disclose fully and truly all the material facts necessary for its assessment, but on the basis of an audit objection raised by the internal audit party. Apart from that, there was no whisper in the “reasons to believe” that the case of the assessee was being reopened for any failure on its part to disclose fully and truly material facts that were necessary for its assessment for the year under consideration. Thus, the reopening was not maintainable and the assessment framed by the Assessing Officer under section 143(3) read with section 147, was liable to be quashed for want of valid assumption of jurisdiction by the Assessing Officer. (AY. 2008-09)