A notice for reopening of assessment was issued beyond a period of our  years from the end of the relevant  assessment year  on three grounds. With respect to the first ground of cessation of liability, the assessee had transferred the outstanding interest in inter-branch accounts to the P&L Account. Since all the relevant details with respect to this issue were already filed in the course of original assessment, there was no failure on the part of the assessee to disclose truly and fully all material facts. With respect to the second ground, the assessee had in the original return of income offered a capital gain of Rs. 4.68 crores to tax, which was erroneously written as Rs. 44.68 crore in the assessment order. The assessee filed a rectification application before the AO which was accepted and the mistake rectified. In the reopening notice, the AO has contradicted himself by saying that the correct amount of capital gain was not offered to tax. Reopening cannot be sustained on this ground either. In the third ground, the AO argued that in calculating dividend distribution tax, the assessee was allowed to deduct only the dividend received from the subsidiaries in the given financial year. With respect to this ground too, the assessee had truly and fully disclosed all the relevant facts in the original assessment proceedings. The reopening was therefore to be quashed. ( Referred  Dr.Amin’s Pathology Laboratory  ( 2001) 252 ITR 673 ( Bom) (HC) Raymond Woollen Mills  Ltd v ITO (1999) 236 ITR  34 (SC) ( WP no . 3588 of 2018 dt. 17-01 -2019) (AY. 2011-12)