Held that the reason to believe therefore could not be said to be based on any new or fresh tangible material and could not therefore be used as a tool to reopen the assessment proceedings. The assessment had been reopened beyond a period of four years, and it was not a case where it could be said that the assessee had failed to disclose fully and truly all material facts necessary for his assessment. The notice of reassessment was not valid (AY.2011-12)