The Tribunal held that  the AO nowhere alleged that the income assessable to tax has escaped assessment due to the failure of the assessee to disclose fully and truly all material facts necessary for his assessment. The reopening of the assessment was after four years from the end of the relevant assessment year. When the AO had not even alleged the failure on the part of the assessee to disclose fully and truly all material facts necessary for assessment then, the reopening after four years was not sustainable as it was hit by the proviso to section 147. The CIT had granted approval twice and the first approval bore the date as April 14, 2014 whereas the second set bore the date March 14, 2014. There could not be two approvals of the same reasons recorded by the AO for  issuing the notice under S.  148. The reopening was not valid.  As regards seized material  not containing  any incriminating materials, addition is held to be not justified. (AY. 2007-08, 2008-09)