Assessee filed its return of income which was accepted and an assessment order was passed. The  Assessing Officer issued a reopening notice after period of four years on ground that guarantee fee claimed by assessee pertaining to financial year 2013-14 but booked in financial year 2015-16 was not allowable in assessment year 2014-15. On writ the Court held that the  reasons for reopening did not allege any failure on part of assessee to disclose fully and truly all material facts anywhere in assessment. There was no fresh tangible material which would empower Assessing Officer to reopen assessment.Further, issue of ‘guarantee fee’ was pending consideration before Tribunal and thus Assessing Officer was debarred from initiating reassessment proceedings on that very issue.Reassessment proceedings  was  quashed.  (AY. 2014-15)