Allowing the petition the Court held that the jurisdictional parameters prescribed in the proviso to section 147 that the assessee failed to disclose fully and truly all material facts necessary for assessment, were not fulfilled. There was no allegation in the notices or the reasons furnished that the assessee had failed to disclose fully and truly all material facts necessary for assessment for the assessment year 2015-16 or that there was suppression of income resulting in escapement from assessment. Such failure was a jurisdictional parameter which must have been fulfilled to sustain the notice issued for reassessment under section 148 after the expiry of four years from the end of the relevant assessment year. The justification belatedly offered in the order rejecting the assessee’s objections could not be regarded as a valid defence of the notice under section 148. The notice and order rejecting the assessee’s objections were quashed and set aside. (AY.2015-16)