Allowing the petition the Court held that the reasons for reopening the assessment did not point to any new material that was available with the Department. The same material, viz., the accounts produced by the assessee were re-examined and a fresh opinion was arrived at. In fact, a questionnaire had been issued by the Assessing Officer in the course of the original assessment proceedings to the assessee to which the assessee had responded. Reassessment notice was quashed. (AY.2009-10)